ipswich.gov.uk
CS13: Planning for Jobs Growth
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5154
Received: 04/03/2015
Respondent: clive gissing
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Without properly defined specific and measurable jobs growth objectives the CS is unsound. To improve clarity and effectiveness 2 jobs targets are required: one for the Borough and one for outside. Measurement indicators should be specified. A recent report by Peter Brett Associates calls into question the viability of developing new offices, industrial units, warehousing and large retail offerings within Ipswich. This challenges the ability of the CS to deliver the massive jobs growth target. For soundness the CS needs to address the severe obstacle to growth identified and produce a specific and realistic jobs target for Ipswich Borough.
Without properly defined specific and measurable jobs growth objectives the CS is unsound. To improve clarity and effectiveness 2 jobs targets are required: one for the Borough and one for outside the Borough. Measurement indicators should be specified.
A recent report by Peter Brett Associates (listed on the IBC website) calls into question the viability of developing new offices, industrial units, warehousing and large retail offerings within Ipswich. This challenges the ability of the CS to deliver the massive jobs growth target. For soundness the CS needs to address the severe obstacle to growth identified and produce a specific and realistic jobs target for the Borough of Ipswich.
Support
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5223
Received: 05/03/2015
Respondent: Associated British Ports
Agent: Associated British Ports
ABP welcomes and supports the definition of its land at the Port of Ipswich (at the West Bank and Cliff Quay) as existing employment areas defined on the policies map and the protection of this land for employment uses. This is consistent with the Port's recognition in the NALEP Strategic Economic Plan as part of the port and logistics 'underpinning sector' for the regional economy and the recognition given in the DPD Review of the strategic role and importance of the Port of Ipswich (at paragraphs 5.6, 6.19 and 9.153 - 9.154).
ABP supports Policy CS13(b).
The Port of Ipswich provides an extensive range of facilities to meet the needs of businesses and industry based in Norfolk and Suffolk. It is the UK's leading grain exporter and largest of ABP's short-sea ports handling containers, dry bulks, forest products, general cargo and offering extensive roll-on roll-off facilities. The total port area (including water) is approximately 275 acres (111 ha) and the Port handles approximately two million tonnes of goods per year. The Port is rail connected and can offer intermodal services from the port to inland facilities including rail terminals such as ABP's own Hams Hall Railfreight Terminal in the Midlands. The Port is also the base for expanding Marina activities. Together with ABP's other East Anglian Ports at Kings Lynn and Lowestoft, the Port contributes some £241m directly into the regional economy and supports 3,577 jobs in the area.
The key strategic challenges for Ipswich identified at paragraph 5.25 of the Core Strategy and Policies DPD Review emphasise the need to manage and gain best benefit from further significant growth in all its forms. This is not restricted to housing - it includes economic activity - including the 'significant role' of the Port which can drive further growth in the region through future expansion (consistent with the Port's recognition in the NALEP Strategic Economic Plan and at paragraphs 5.6, 6.19 and 9.153 - 9.154 of the Core Strategy and Policies DPD Review).
Given that the Core Strategy seeks to focus the provision of a significant number of Ipswich's new homes within central Ipswich (paragraph 6.17), and that important elements of the Port are within or adjacent to central Ipswich, one of the more detailed issues that the Core Strategy and Policies DPD Review should identify is the need for these (sometimes competing) requirements to be sensitively addressed and balanced. This is the context in which ABP's representations are made.
ABP welcomes and supports the definition of its land at the Port of Ipswich (at the West Bank and Cliff Quay) as existing employment areas defined on the policies map and the protection of this land for employment uses. This is consistent with the Port's recognition in the NALEP Strategic Economic Plan as part of the port and logistics 'underpinning sector' for the regional economy and the recognition given in the DPD Review of the strategic role and importance of the Port of Ipswich (at paragraphs 5.6, 6.19 and 9.153 - 9.154).
ABP supports Policy CS13(b).
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5319
Received: 05/03/2015
Respondent: Mrs Valerie Bryne
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
What evidence is there that 12,500 jobs can be created, all the major employers have left Ipswich. There has been no major jobs growth since 2001. Where will the jobs come from?
What evidence is there that 12,500 jobs can be created, all the major employers have left Ipswich. There has been no major jobs growth since 2001. Where will the jobs come from? (From attached representation)
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5401
Received: 03/03/2015
Respondent: Northern Fringe Protection Group
Number of people: 323
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Based on past trends, jobs are unlikely to grow by 625pa to 2031. EEFM forecasts are based on higher population projections than ONS projections and the sectors forecast to grow don't align with the Strategic Economic Plan. There is over-reliance on retail jobs. The target may not be achievable without government funding and improved transport infrastructure. Job forecasts in the Core Strategies of Ipswich and neighbouring authorities are 26% higher than EEFM and are unrealistic. Unclear whether the target relates to Ipswich or the Ipswich Policy Area. If the latter a separate jobs target must be established. Indicators are needed.
See attachment
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5470
Received: 05/03/2015
Respondent: AquiGen
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
We note that the Site continues to be allocated as a 'Strategic' Employment Site. This is on the basis that approximately 10ha of land is safeguarded for B Class employment use (see CS paragraph 8.139). AquiGen objects to the Site's designation as 'Strategic' as this is not justified by the Evidence Base and is no longer required. Market conditions and signals provide evidence that the site does not serve a strategic function.
We note that the Site continues to be allocated as a 'Strategic' Employment Site. This is on the basis that approximately 10ha of land is safeguarded for B Class employment use (see CS paragraph 8.139). AquiGen objects to the Site's designation as 'Strategic' as this is not justified by the Evidence Base and is no longer required. The reasons for this are outlined below
The rationale for this designation and its status as 'Strategic' is stated to be justified on the basis that there was capacity for readily serviceable regionally significant strategic sites in the Haven Gateway (see CS paragraph 8.138) as identified in the RSS. The Site was identified to serve such a purpose in Ipswich as identified in the October 2009 Employment Land Review ("ELR"). The RSS now has no status for the purposes of Development Plan policy and the ELR is over 6 years old (when consideration is given to the data sources) and has not been the subject of an update as part of this CS Review. The Evidence Base justification relating to the need for and identification of the Site as a 'Strategic' Employment Site is accordingly significantly out-of-date for the purposes of NPPF paragraphs 158/161 and the PPG (Paragraph: 014 / Reference ID: 12-014-20140306). On this basis it cannot be relied upon for
plan-making purposes. In order to address this deficiency, we note that the CS seeks to
place reliance on the more recent Suffolk Growth Strategy ("SGS") and New Anglia Strategic Economic Plan ("SEP") documents. In this regard, the SGS does identify the Site as a Key Development Site (see paragraph 7.11). However, the growth objectives/sector priorities identified in either of these documents do not readily align with the planning permission which already exists for the Site and which does not appear to have been recognised.
The regional documents cannot be relied upon for the purposes of Evidence Base as they do not offer evidence on the key requirements listed at NPPF paragraph 161 as it relates to economic development. Nor can they be relied upon in relation to Objectively Assessed Need ("OAN") for Economic Development in line with PPG (Paragraph: 001 / Reference ID: 2a-001¬20140306).
Against this background, there is clearly no up-to-date and reliable evidence base upon which to test and formulate land use policies and requirements for Employment development. There is also no Evidence Base justification to justify the Site's identification as 'Strategic' in terms of the OAN for Economic Development.
We note that since the publication of the CS Review for consultation the Council has produced an Employment Topic Paper, which indicates that an Employment Land Needs Assessment is now being carried out for the Ipswich Functional Economic Market Area. We assume that this seeks to address the clear evidential deficiency which we have identified.
We shall clearly wish to review and comment upon this document in due course. For the moment, however, it should be noted that the Topic Paper serves to record the very significant supply of employment land against a low take up rate and expressly acknowledges the weakness of the Ipswich industrial/ office market.
As far as the Site itself is concerned, the Topic Paper simply restates its status as a Strategic site and offers no evidence in support of this continued designation. Futhermore, the suggestion within the appended Job Capacity Estimates that the undeveloped portion of the site is capable of generating in excess of 2,000 jobs has clearly not been calculated with reference to the mix of uses embodied in the current Planning Permission.
The Topic Paper's acknowledgment of market weakness accords with AquiGen's own experience. Since the Company's involvement in the formulation and delivery of the Site extends back to 2009, it has an extensive and clear understanding of the local and sub-regional economic factors that relate to the Site. Based on its experience of monitoring schemes and tracking potential opportunities together with advice from its commercial property agents, AquiGen is aware that the uptake of industrial land in the area is indeed slow. Requirements in the Ipswich policy area for land or the re-occupation / development of industrial buildings tend to originate from localised requirements generated by local businesses or national operations which require small-scale support facilities and / or expanded operations. The local market does not attract significant and strategic inward investment or relocation which is reflected in the low level of industrial land delivery since 2009. This is not expected to change.
These market conditions are reflected in the level and nature of enquiries for the Site received by AquiGen. These relate to local businesses and interests that have identified the Site as a potential relocation or expansion opportunity. There have been no strategic or significant inward investment opportunity enquiries that have been received within the B Class sector. On this basis, market conditions and signals provide clear evidence that the Site does not serve a strategic function.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5491
Received: 05/03/2015
Respondent: Mr Andrew Fisk
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Frankly I see little chance of more people cycling or walking without the creation of local jobs and I do not see where these will come from (CS13).
Transport policy, (CS5, CS17 and CS20) There doesn't seem to be any realistic attempt to deal with the additional traffic that will result from the Northern fringe development. There are some changes which will increase the area of road for traffic to queue on, but they do not fundamentally address the problem of traffic movement. The roads to and from the development are already extremely busy and there does not seem a suitable way of expanding the capacity of the existing roads (Valley Road, Henley Road etc.) to accommodate this traffic. I believe that increased congestion is likely, which in turn is liable to cause more pollution both in terms of air quality and noise (CS1). Valley road/ Colchester road etc. is also the route used when the Orwell bridge is unavailable, I believe that an alternative route, preferably one that allows access to and from the new development should be undertaken as part of the strategy for this site. The proposed changes around the docks may make a difference, but they would need to be undertaken in advance of this development in order to make a difference. Frankly I see little chance of more people cycling or walking without the creation of local jobs and I do not see where these will come from (CS13).
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5512
Received: 05/03/2015
Respondent: Ipswich Liberal Democrats
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Most of the allocated land and current jobs are on the south/east side of Ipswich or the Town Centre. Planning for a large mainly housing development on the Northern Fringe, essentially functioning as a dormitory for people employed elsewhere, will result in even more congestion.
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5561
Received: 27/02/2015
Respondent: Westerfield Parish Council
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The policy indicates that housing allocation is mainly justified by job growth in the Ipswich Policy area. Job growth has stalled over the last few years and the global economic growth forecast for the foreseeable future is not good. Although we support job growth, the figure of 12,500 within the Ipswich boundary which equates to a 17% increase, seems optimistic.
Policy CS13 Job Growth.
The policy indicates that housing allocation is mainly justified by job growth in the Ipswich Policy area. Job growth has stalled over the last few years and the global economic growth forecast for the foreseeable future is not good. Although we support job growth, the figure of 12,500 within the Ipswich bounday which equates to a 17% increase, seems optimistic. Also recent evidence of national job growth suggests that a proportion is in part time or zero contract positions. The forecast model used to assess the housing requirement based on job growth prediction should take the above caveat into consideration when predicting housing needs.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5574
Received: 25/02/2015
Respondent: Ipswich Conservative Group
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The Plan's strategy is no longer employment led, but has been changed to a housing needs led strategy - 13,350 new dwellings to be built by 2031. The result is that the jobs target has fallen out of kilter with the housing target. This is a move in the wrong direction as the emphasis on housing reduces the priority that should be put on jobs.
The Plan's strategy is no longer employment led, but has been changed to a housing needs led strategy - 13,350 new dwellings to be built by 2031. The result is that the jobs target has fallen out of kilter with the housing target. This is a move in the wrong direction as the emphasis on housing reduces the priority that should be put on jobs. The town cannot support an increasing population (forecast to rise from 133,384 in 2011 to 154,000 in 2031) without a large increase in jobs. The Council's strategy will inevitably result in "too many people chasing too few jobs".
Housing growth must be matched by employment growth. There is a need to ensure that enough jobs are created for the population living in the new housing developments. There is insufficient emphasis on employment in the Strategy which will lead to an imbalance between jobs and homes. Ideally jobs and homes should be in balance and in close proximity with good transport links. However, the strategy provides for the bulk of new housing in the town to be in the Ipswich Garden Suburb, whilst the major employment sites are some distance away e.g. Ransomes Europark, Ravenswood. Other people living in the Garden Suburb will have to look for employment further afield including travelling to London. This will lead to a significant increase in commuting with all the adverse effects this will have on traffic congestion and air quality in the town. The Strategy fails to provide a positive approach to job creation. The target of 12,500 by 2031 may well prove to be unrealistic, particularly as it represents an annual increase in employment which is well in excess of the number of jobs created in the town each year in the past twenty years. Recent years have seen significant growth in population and housing, but lesser growth in jobs.
The Strategy contains no phased targets for job creation over the period. Moreover, there is no link between the land allocated for employment and job creation. The number of jobs will depend on the type of businesses that develop the land. If capital intensive industries move to the town, the number of additional jobs created will be limited.
By emphasising housing rather than employment, the Strategy has severe limitations. It may well encourage the construction of a significant number of additional houses, but those houses will not be located near to new jobs - even if those jobs exist at all.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5585
Received: 25/02/2015
Respondent: Mr Cyril Eden
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
A recent report by Peter Brett Associates (listed on the IBC website) calls into question the viability of developing new offices, industrial units, warehousing and large retail offerings with Ipswich. This challenges the ability of the CS to deliver the massive jobs growth target. For soundness the CS needs to address the severe obstacle to growth identified and produce a specific and realistic jobs target for the Borough of Ipswich.
See attachment
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5587
Received: 05/03/2015
Respondent: Save Our Country Spaces
Legally compliant? No
Sound? No
Duty to co-operate? No
The target of 12,500 jobs to be delivered 2011-2031 is unrealistic and undeliverable as to date there has been no real jobs growth since 2001 and public sector jobs are set to reduce. This is unsustainable and non compliant with the NPPF. SOCS support the aspiration but believe that according to our research and evaluation over time, since 2001, that there is no indication as to how this can or will be achieved. Endorse the Northern Fringe Protection Group's points also.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5607
Received: 25/02/2015
Respondent: Mrs Mavis Hammond
Legally compliant? Not specified
Sound? No
Duty to co-operate? No
A report by Peter Brett Associates calls into question the viability of developing new offices, industrial units, warehousing and large retail offerings with Ipswich. This challenges the ability of the CS to deliver the massive jobs growth target. For soundness the CS needs to address the severe obstacle to growth identified and produce a specific and realistic jobs target for the Borough of Ipswich. The jobs target of in the region of 12,500 jobs is unrealistic and undeliverable This is unsustainable and not compliant with the National Planning Policy Framework (NPPF).
See attachment
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5637
Received: 16/02/2015
Respondent: Mr Tony Moran
Legally compliant? Not specified
Sound? No
Duty to co-operate? No
There is little clear evidence that the number of new jobs referred to in Para 6.8 Objective(b) & CS13
are a realistic forecast. With the decline in local government employment and that of other local major employers, the generation/origin of 2500 net new jobs needs to be properly spelt out.
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5659
Received: 05/03/2015
Respondent: Mrs Jane Catling
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
A recent report by Peter Brett Associates (listed on the IBC website) calls into question the viability of developing new offices, industrial units, warehousing and large retail offerings with Ipswich. This challenges the ability of the CS to deliver the massive jobs growth target. For soundness the CS needs to address the severe obstacle to growth identified and produce a specific and realistic jobs target for the Borough of Ipswich.
See attachment
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5665
Received: 28/02/2015
Respondent: Mrs Helen Mason
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Where will people in the 12,500 new jobs go for medical assistance? Concerned that there are no plans for improved hospital or GP facilities to cope with increased usage.
See attachment
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5674
Received: 03/03/2015
Respondent: Mr Bridges
Legally compliant? Not specified
Sound? No
Duty to co-operate? No
The jobs target of in the region of 12,500 jobs is unrealistic and undeliverable as to date there has been no real job growth since 2001 and public sector jobs are set to reduce. This is unsustainable and not compliant with the National Planning Policy Framework (NPPF).
See attachment
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5684
Received: 03/03/2015
Respondent: Mrs Bridges
Legally compliant? Not specified
Sound? No
Duty to co-operate? No
The jobs target of in the region of 12,500 jobs is unrealistic and undeliverable as to date there has been no real job growth since 2001 and public sector jobs are set to reduce. This is unsustainable and not compliant with the National Planning Policy Framework (NPPF).
See attachment
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5689
Received: 03/03/2015
Respondent: Mrs Chris Wall
Number of people: 2
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Not enough jobs in central Ipswich to warrant all the new housing
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5690
Received: 02/03/2015
Respondent: Mr Julian Mason
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Assumptions regarding jobs growth. To achieve the projected numbers of new jobs, Ipswich would have to enjoy economic growth far in excess of the current situation here or elsewhere nationally. Please identify the special features of the local economy that would justify this exceptional growth. Without convincing evidence that these figures are achievable, many other elements of the strategy are put in doubt. A recent report by Peter Brett Associates questions the viability of developing new offices, industrial units, etc. within Ipswich. This also calls into doubt the likelihood that the ambitious growth figures will be achieved.
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5748
Received: 03/03/2015
Respondent: D C Norman
Legally compliant? Not specified
Sound? No
Duty to co-operate? No
The jobs target of in the region of 12,500 jobs is unrealistic and undeliverable as to date there has been no real job growth since 2001 and public sector jobs are set to reduce. This is unsustainable and not compliant with the National Planning Policy Framework (NPPF).
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5757
Received: 02/03/2015
Respondent: Mr Brian Pinner
Legally compliant? Not specified
Sound? No
Duty to co-operate? No
The jobs target of in the region of 12,500 jobs is unrealistic and undeliverable as to date there has been no real job growth since 2001 and public sector jobs are set to reduce. This is unsustainable and not compliant with the National Planning Policy Framework (NPPF).
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5773
Received: 25/02/2015
Respondent: Mr Brian Pachent
Legally compliant? Not specified
Sound? No
Duty to co-operate? No
The jobs target of in the region of 12,500 jobs is questionably realistic This is questionably sustainable and questionally compliant with the National Planning Policy Framework (NPPF).
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5780
Received: 03/03/2015
Respondent: Mr & Mrs David and Pamela McCartney
Number of people: 2
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The jobs target of in the region of 12,500 jobs is unrealistic and undeliverable as to date there has been no real job growth since 2001 and public sector jobs are set to reduce. This is unsustainable and not compliant with the National Planning Policy Framework (NPPF).
See attachment
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5803
Received: 05/03/2015
Respondent: Yvonne Maynard
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The proposed retail and shopping centre plan is unachievable, do not understand how 12500 jobs will be created.
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5810
Received: 05/03/2015
Respondent: Mr Philip Maynard
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Do not understand how 12500 jobs will be created, the retail and shopping centre plan is unachievable
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5824
Received: 05/03/2015
Respondent: Mrs Creasey
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Question the jobs target of in the region of 12,500 jobs is unrealistic and undeliverable as to date there has been no real job growth since 2001 and public sector jobs are set to reduce. This is unsustainable and not compliant with the National Planning Policy Framework (NPPF).
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5834
Received: 05/03/2015
Respondent: Mr John Summers
Legally compliant? Yes
Sound? No
Duty to co-operate? No
The jobs target of in the region of 12,500 jobs is unrealistic and undeliverable as to date there has been no real job growth since 2001 and public sector jobs are set to reduce. This is unsustainable and not compliant with the National Planning Policy Framework (NPPF).
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5845
Received: 05/03/2015
Respondent: Mrs Jennifer Summers
Legally compliant? Yes
Sound? No
Duty to co-operate? No
The jobs target of in the region of 12,500 jobs is unrealistic and undeliverable as to date there has been no real job growth since 2001 and public sector jobs are set to reduce. This is unsustainable and not compliant with the National Planning Policy Framework (NPPF).
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5856
Received: 05/03/2015
Respondent: Mr Neil Summers
Legally compliant? Yes
Sound? No
Duty to co-operate? No
The jobs target of in the region of 12,500 jobs is unrealistic and undeliverable as to date there has been no real job growth since 2001 and public sector jobs are set to reduce. This is unsustainable and not compliant with the National Planning Policy Framework (NPPF).
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5867
Received: 05/03/2015
Respondent: Miss Charlotte Miller
Legally compliant? Yes
Sound? No
Duty to co-operate? No
The jobs target of in the region of 12,500 jobs is unrealistic and undeliverable as to date there has been no real job growth since 2001 and public sector jobs are set to reduce. This is unsustainable and not compliant with the National Planning Policy Framework (NPPF).
See attached