Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Object

Representation ID: 26468

Received: 02/03/2020

Respondent: Associated British Ports

Agent: Associated British Ports

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Island Site is situated within the Waterfront area to which this policy applies. As noted at para 5.21, parts of the operational port are also within it. ABP notes the desire of IBC to secure high density development in the interests of maximising the use of previously developed land, subject to that not compromising heritage assets and the historic character of Ipswich. ABP’s vision for the site (agreed with the partners and the LEP) does not envisage ‘high density’ development as currently defined in Policy DM23. ABP request additional wording in the final paragraph of Policy CS2.

Object

Representation ID: 26469

Received: 02/03/2020

Respondent: Associated British Ports

Agent: Associated British Ports

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Support regeneration objectives for IP-One area. Important elements of the Port within or adjacent to area. Development should have regard to existing port uses/activities to ensure they are protected. Concerned to ensure right and ability to use land and infrastructure for port purposes is retained and Port’s 'significant (economic) role' and ability to expand is protected. Request that recognition is made to the Port and other important existing employment/activities within/adjoining IP-One area which the Council wishes to safeguard and support. Development should be sensitive to existing uses and avoid potential impacts which may prejudice the continued operation/expansion of these uses.

Object

Representation ID: 26470

Received: 02/03/2020

Respondent: Associated British Ports

Agent: Associated British Ports

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

ABP welcomes IBC’s policy on housing type and tenure mix and the recognition of potential exceptions to these requirements in response, for example, to viability constraints. ABP also notes the desire of IBC to secure high density development on central sites (para 8.121) which will also assist viability. However, high density may not be appropriate in all instances.

Support

Representation ID: 26471

Received: 02/03/2020

Respondent: Associated British Ports

Agent: Associated British Ports

ABP notes the requirement for major new development (10+ dwellings) to provide 15% affordable housing and welcomes the flexibility within the wording of Policy CS12 both in respect of the proportion of affordable housing and tenure mix where development viability justifies it.

Support

Representation ID: 26472

Received: 02/03/2020

Respondent: Associated British Ports

Agent: Associated British Ports

ABP welcomes and supports the inclusion in Policy CS13 of reference at sub-point b. to the need to protect “land for employment uses in existing employment areas defined on the policies map, including the function and strategic role of the port to Ipswich” in response to ABP’s specific request for such reference in the previous Core Strategy and Policies Development Plan Document Review Preferred Options.

Object

Representation ID: 26473

Received: 02/03/2020

Respondent: Associated British Ports

Agent: Associated British Ports

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Welcome intention to make case for highway improvements including Wet Dock Crossing. Support recognition (para 8.243) that provision of Wet Dock Crossing is not a pre-requisite of access improvements to enable development. Whilst supportive of redevelopment of Island Site, delivery is dependent on commercial viability. Until satisfactory scheme agreed, reserve right to use site as operational port area and to restrict access. Disagree with reference to requirement of road bridge to enable development at Island Site (para 8.247) - request removal. Access required will depend on development - reduced density of approximately 150 units, may not require additional vehicular access.

Object

Representation ID: 26474

Received: 02/03/2020

Respondent: Associated British Ports

Agent: Associated British Ports

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

ABP is supportive of IBC’s desire for all new development to be well designed and sustainable, for 25% of new dwellings to be built to Building Regulations standard M4(2), and for proposals to respect the special character and distinctiveness of Ipswich including ensuring good public realm design. However, this should not be at the expense of development viability and the policy should be applied flexibly in the context of the objective to achieve sustainable regeneration.

Object

Representation ID: 26475

Received: 02/03/2020

Respondent: Associated British Ports

Agent: Associated British Ports

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Objection to reference in Policy under section titled ‘Conservation Areas’ to the demolition of buildings and to the consideration by the Council of “the withdrawal of permitted development rights where they present a threat to the protection of the character and special interest of the conservation area”. ABP benefits from ‘permitted development’ rights over its ‘operational land’. Reliance on these rights is critical to the ability to fulfil its statutory duties. Strongly resist any steps to withdraw permitted development rights. If reference to withdrawal of permitted development rights does not encompass those enjoyed by ABP, specific clarification should be included.

Support

Representation ID: 26476

Received: 02/03/2020

Respondent: Associated British Ports

Agent: Associated British Ports

ABP welcomes IBC’s qualification that it will not insist on the requirement to meet Nationally Described Space Standards if this is demonstrated to be unviable in specific cases.

Support

Representation ID: 26477

Received: 02/03/2020

Respondent: Associated British Ports

Agent: Associated British Ports

ABP supports the safeguarding of the operational areas of the Port through their definition as Employment Areas E9 and E12 on the Policies Map and under Policy DM33. Welcome the recognition at para 9.33.6 of the need for ABP’s specific operational requirements and consents and licences for the handling and storage of hazardous substances to be taken into account in any development planned in the vicinity of these areas.