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relating to the need for and identification of the Site as a 'Strategic' Employment Site is accordingly significantly out-of-date for the purposes of NPPF paragraphs 158/161 and the PPG (Paragraph: 014 / Reference ID: 12-014-20140306).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.

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