Comment

Representation ID: 24704

Received: 24/10/2017

Respondent: Suffolk Preservation Society

DM5 only criteria e and f refer to special townscape character and architectural quality-inadequate to deliver high quality design. should be more specific and robust. SCDC Design Policy DM21 is a better example.
DM34 Countryside - criteria a and g incompatible because a major housing development is unable to respect the character of countryside - defined by low density, sparse housing and open spaces. Fails to specify sequential site selection which supports brownfield before greenfield. Wording of policy fails to include "enhance" when referring to statutory duty with regard to the AONB in line with S85 of CROW Act.

Comment

Representation ID: 24710

Received: 24/10/2017

Respondent: Suffolk Preservation Society

Policy DM8 lacks a positive statement setting out the approach of the management of the historic environment. We refer you to Colchester Borough Council Policy, DP14: Historic Environment Assets, as a good example

Comment

Representation ID: 24740

Received: 30/10/2017

Respondent: RSPB

Agent: RSPB

Policy DM6 - Additional line k) to incorporate integrated swift-bricks
Policy DM10 - Re-word as Protection and Enhancement of trees and hedgerows
Policy DM28 - We question the tone of this policy. NPPF sets out that open spaces should be protected and enhanced.
Policy DM31 - needs to include SPAs and SSSIs

Comment

Representation ID: 24917

Received: 27/10/2017

Respondent: Historic England

All policies should be reviewed through this process and consideration of the historic environment given throughout the plan to form a positive strategy. Please read this answer alongside our other answers to this consultation, especially Q84. We highlight these particular policies for consideration on how they can be improved: CS4, DM5, DM6, DM8, DM9, DM30. This review is an opportunity to refine the approach to the Waterfront area. The current structure of the IP-One Opportunity Areas and the site allocations has not provided the clarity and vision required or adequately set out the complex historic environment considerations in this area.

Comment

Representation ID: 24976

Received: 25/10/2017

Respondent: Northern Fringe Protection Group

Yes. The DM policies need to take better account of the major air quality issues affecting Ipswich. Air quality must be improved and all AQMAs eradicated. Development should not be permitted if it risks worsening air quality.

Comment

Representation ID: 25017

Received: 30/10/2017

Respondent: Suffolk Wildlife Trust

Policy DM4 - could be amended to ensure that all new SuDS are designed to maximise their wildlife value in accordance with published best practice guidance.

Policy DM5 and DM6 - could be amended to ensure that the design of new developments secures enhancements for wildlife.

Policy DM29 - New sports and recreation facilities can represent significant areas of greenspace, the policy should therefore ensure that such development maximises the biodiversity opportunities of such sites.

Policy DM31 - We support this policy, however it may be necessary to update Plan 5 (Ipswich Ecological Network).

Comment

Representation ID: 25056

Received: 31/10/2017

Respondent: Save Our Country Spaces

Yes. The DM policies need to take better account of the major air quality issues affecting Ipswich. Air quality must be improved and all AQMAs eradicated. Development should not be permitted if it risks worsening air quality.

Comment

Representation ID: 25070

Received: 30/10/2017

Respondent: On behalf of EDF Energy

Regarding policy CS2, we propose that new development should also be encouraged within sustainable areas and there should be a preference for development on brownfield land. With regard to density, there should also be some flexibility with the application of density standards, depending on the character of the area and accessibility levels. In certain situations, outside of the town centre, it may be possible to achieve higher densities and each site should be assessed on a site specific basis. This approach is consistent the NPPF (paragraph 17), which encourages effective use of land.
Policy CS12 - We support the Council's approach in that the Council recognises that where it is difficult to meet the target for affordable housing provision, a lower amount of affordable housing or different tenure mix could be provided on a site, subject to viability testing in accordance with the NPPF. However, the policy does not provide for off -site affordable housing or commuted payments in lieu of on-site provision. It would be helpful to provide these alternative arrangements within the policy, especially where viability assessments support this approach as a preferred option.
Policy CS9 seeks to focus on brownfield land first whilst recognizing that greenfield land will need to be developed to meet the Boroughs housing need and forecasted job growth. This policy has been deleted. We therefore request that this policy be included as part of the emerging Local Plan as there is a priority to build on previously developed land, in line with paragraph 17 of the NPPF.
Policy CS17 - We request that any infrastructure to be secured or financed from new developments towards the provision of highways and transport; childcare, early years and education; health and emergency services; environment and conservation; community and cultural facilities including heritage and
archaeology; sport and recreation; economic development; and utilities are sought in areas where there is an identified deficiency and at a level that ensures that overall delivery of appropriate development is not compromised. This request accords with paragraph 204 of the NPPF which states that planning obligations from development sites must be fair, reasonable and proportionate.
Policy DM25 does not provide for or set out clear guidance around the grounds upon which the Council will permit the conversion, change of use/redevelopment of sites and premises allocated for employment uses to non B1, B2 and B8 uses.
We suggest the Council sets out clear guidance within the policy to permit this only
where:
- 'there is no reasonable prospect of the site being re-used for employment purposes over the plan period;
- The proposed use is compatible with the surroundings; and
- 6 months marketing evidence is provided to demonstrate the lack of demand for the land'

Comment

Representation ID: 25081

Received: 23/11/2017

Respondent: Associated British Ports

CS3 - ABP supports the regeneration objectives for the IP-One area. There are, however, important elements of the Port within or adjacent to this area. New development should, therefore, have regard to these existing uses and activities so as to ensure that they are protected. We suggest, therefore, the addition of a new criterion into any new policy based on Policy CS3:
"New development should be sensitive to existing uses (including those at the Port of Ipswich) and avoid potential impacts which may prejudice the continued operation and where appropriate, expansion of these uses."
CS20 - Policy needs to be updated to reflect progress since the DPD was adopted. ABP asks only that any update has regard to and reflects ABP's concerns that any new transport scheme:
1) avoids an unacceptable impact on existing vessel access to the Wet Dock via the Lock Pit to the detriment of continued port operations and those of our tenants, commercial businesses and the vitality and viability of the Ipswich Haven Marina
2) avoids any adverse impact (e.g. through traffic congestion) on Cliff Road, which is the primary access
onto Cliff Quay
3) avoids any adverse impact on the route for port operational vehicles, plant and equipment between
Cliff Quay and the Island Site
4) avoids a routing which would affect the existing railhead into the West Bank Terminal
5) does not prevent the Port from meeting the stringent security requirements of the International Ship
and Port Facility Security Code, and
6) allows for navigation rights along the New Cut

Comment

Representation ID: 25375

Received: 30/10/2017

Respondent: Mr Matt Clarke

Boss Hall - We generally support the existing development management Policy DM25 as it provides protection for employment land. However, we also consider that reference should be made to preventing the long term protection of employment land where there is no reasonable prospect of a site being used for that purpose.

Prince of Wales Drive - In the context of this question that development management policies relating to areas such as proposals in retail areas are to be amended as a result of more up-to-date evidence in the form of the new Retail and Leisure Study.

Comment

Representation ID: 25456

Received: 30/10/2017

Respondent: Suffolk County Council

The County Council would appreciate the opportunity to review Ipswich Borough Council's development management policies with Borough officers, once consideration has been given to the other comments made in respect of the development of this Plan.

Comment

Representation ID: 25486

Received: 30/10/2017

Respondent: Mr Arwel Owen

Our experience in the IGS demonstrates that viability and pragmatic policy decisions are central to securing delivery. Our policy representations over the last decade have continually sought to ensure that policies have been realistically framed to allow them to be met, rather than being expressed as aspirational and then failing to be upheld. We have consistently argued that polices relating to the proportion of affordable housing to be delivered, and to the sustainability standards to be achieved in new built schemes should be expressed on a realistic basis and consistent with national policy.

Comment

Representation ID: 25499

Received: 24/10/2017

Respondent: Suffolk Constabulary

Yes. HMO's can put disproportionate pressure onto local neighbours, parking provision and noise, which can lead to conflict.
Maintaining a high quality of HMO's is essential to ensure the safety of the residents therein, as well as neighbouring properties. This should be reflected in policy DM14.