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

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Object

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

Policy CS2 The Location and Nature of Development

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

Representation Summary:

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.

Change suggested by respondent:

Policy CS2 should be amended as follows “…and low elsewhere, unless otherwise agreed through masterplans and provided that in all areas it does not compromise heritage assets.. “ or wording of similar effect.

Attachments:

Object

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

Policy CS3 IP-One Area Action Plan

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

Representation Summary:

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.

Change suggested by respondent:

Request 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.”
Note and support the inclusion of similar wording to this effect in Policy CS13.

Attachments:

Object

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

Policy CS8 Housing Type and Tenure

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

Representation Summary:

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.

Change suggested by respondent:

Not specified

Attachments:

Support

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

Policy CS12 Affordable Housing

Representation ID: 26471

Received: 02/03/2020

Respondent: Associated British Ports

Agent: Associated British Ports

Representation Summary:

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.

Change suggested by respondent:

N/A

Attachments:

Support

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

Policy CS13 Planning for Jobs Growth

Representation ID: 26472

Received: 02/03/2020

Respondent: Associated British Ports

Agent: Associated British Ports

Representation Summary:

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.

Change suggested by respondent:

N/A

Attachments:

Object

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

Policy CS20 Key Transport Proposals

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

Representation Summary:

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.

Change suggested by respondent:

Not appropriate to be so prescriptive about the need for a new road bridge and we would request the removal of reference to it:
“at a minimum, a road bridge from the west bank to the Island Site…will be required to enable any significant development on the Island”.

Attachments:

Object

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

Policy DM12 Design and Character

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

Representation Summary:

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.

Change suggested by respondent:

Not specified

Attachments:

Object

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

Policy DM13 Built Heritage and Conservation

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

Representation Summary:

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.

Change suggested by respondent:

Not specified

Attachments:

Support

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

Policy DM23 The Density of Residential Development

Representation ID: 26476

Received: 02/03/2020

Respondent: Associated British Ports

Agent: Associated British Ports

Representation Summary:

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.

Change suggested by respondent:

N/A

Attachments:

Support

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

Policy DM33 Protection of Employment Land

Representation ID: 26477

Received: 02/03/2020

Respondent: Associated British Ports

Agent: Associated British Ports

Representation Summary:

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.

Change suggested by respondent:

N/A

Attachments:

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