Proposed Submission Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document

On behalf of ALDI stores Ltd, please see representations to Policy SP3 - Land with Planning Permission or Awaiting S106 Agreement with specific reference to the IP090 - Europa Way Site.

Firstly we would reiterate continued support for the allocation of a District Town Centre at Sproughton Road. Following a recent planning application submitted on behalf of ALDI on this site, we are keen to ensure the delivery of a the anchor store element, which will in turn facilitate and encourage wider delivery of other district centre uses across the plan period.

However, there is continued concern in respect of the prescriptive nature of uses being identified for site IPO90, Europa Way, including that uses on the site should be in line with historic planning permissions on the site. It is material that, despite planning permission being in place, not deliverable development proposals have come forward to date and there is significant concern that imposing prescriptive targets for the extent and level of floorspace envisaged in the site will simply delay and prevent investment coming forward. This is quite clearly at odds with NPPF advice to encourage sustainable economic growth without delay.

Furthermore, the policy states that where, 'permissions fail to be issued or implemented and lapse during the plan period, or developments fail to come forward or be completed in accordance with the permission, the Council will protect the sites for residential use or residential-led mixed use.'

It is respectfully submitted that the creation of a District Centre is a key aim of the policy and has been identified as a much needed facility to serve north east Ipswich, including significant housing growth in the area. In order for the new District Centre to compete with other Centres in Ipswich the scheme would be more suited as a commercially led scheme rather than a residential led scheme. This would ensure viability and deliverability of the scheme.

Therefore, we would respectfully request that the Council acknowledges the NPPF which states when pursing sustainable development careful attention should be made to ensure viability and deliverability of schemes. Para 173 states 'plans should be deliverable' and '...should not be subject to such a scale of obligations and policy burdens that their ability to be developed viably is threatened'.

For the avoidance of doubt, it is not suggested that residential is not possible, but rather the scale of residential must be commercially realistic and not impede upon delivery of the commercial element of the District Centre.

We would be most grateful for these comments raised to be taken in to account when going forward in the plan making process.