Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft
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Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft
Chapter 10 - Implementation
Representation ID: 26573
Received: 02/03/2020
Respondent: Suffolk County Council
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Table 8a is not in line with NPPF p.34 which explains that plans should set out the contributions expected from development. The plan needs updating to meet this requirement. Early Years: regarding demand in Gipping Ward, the table states that a new setting (e.g. a day nursery) is required, but no site is stated. IP279 would be the County Council’s preference. Primary provision: Cliff Lane Primary should be added to Table 8a for expansion. Secondary provision: Stoke High School and Chantry Academy are identified for expansion. SCC has reassessed and now considers that only Stoke High School needs to expand.
The County Council will work with the Borough in reviewing the wording and costs in the table and will agree matters through a Statement of Common Ground. Early Years: IP279 would be the County Council’s preferred choice for a setting in Gipping Ward. The site sheet and entry in Table 1 of the Site Allocation Policies document should also be updated in line with this amendment. Primary provision: Cliff Lane Primary should be added to Table 8a (for expansion). Secondary provision: depending on the rate of delivery within Ipswich Garden Suburb, the Council considers that now only Stoke High School needs to expand.
Object
Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft
Policy CS20 Key Transport Proposals
Representation ID: 26574
Received: 02/03/2020
Respondent: Suffolk County Council
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Reference to the Transport Mitigation Strategy for the ISPA is welcome and supported, as is the focus on sustainable transport measures. SCC Transport Model highlights that growth in Ipswich and surrounding districts may cause severe impacts on the highway network within and around Ipswich, which cannot be addressed through improvements to the highway alone. The County Council considers the appropriate strategy to be maximising sustainable transport in order to achieve a significant proportion of modal shift in both the new and existing population. The Suffolk County Council Transport Mitigation Strategy needs to be included in the Local Plan evidence base.
The Suffolk County Council Transport Mitigation Strategy needs to be included in the Local Plan evidence base.
Object
Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft
Policy DM21 Transport and Access in New Developments
Representation ID: 26576
Received: 02/03/2020
Respondent: Suffolk County Council
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
DM21 is not in line with national policy in relation to the lack of explanation as to when travel plans are required. The importance of travel plans in achieving modal shift is stated in the SCC Transport Mitigation Strategy for ISPA. A similar approach should be taken with Travel Plans as for Transport Statements and Assessments. The Plan’s explanatory text should refer to the indicative threshold set out in County Council guidance, with the caveat that in some sensitive areas, e.g. affecting Air Quality Management Areas, full travel plans may be required where normally Travel Plan Measures would be acceptable.
Amendments to the policy are recommended below.
Final paragraph of policy: “The Council will expect (delete: major) development proposals to provide a travel plan or travel plan measures where appropriate, to explain how sustainable patterns of travel to and from the site will be achieved.” Amend paragraph 9.21.8 to further explain the travel plan guidance and what is determined to be appropriate. “The County Council's Suffolk Travel Plan Guidance, which contains indicative thresholds, will be used to determine the need for a Travel Plan or Travel Plan Measures. Some smaller sites which do not meet the requirements for a full Travel Plan, but are in sensitive locations may require a full Travel Plan to help mitigate traffic impacts.”
Object
Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft
Policy ISPA4 Cross Boundary Working to Deliver Sites
Representation ID: 26579
Received: 02/03/2020
Respondent: Suffolk County Council
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The County Council welcomes the commitment to coordinate development across boundaries. This area is outside district or local centres buffers defined on Plan 1. NPPF p.92 states that planning policies should ensure an integrated approach to considering the location of housing, economic uses and community facilities and services. P.103 states that the planning system should limit the need to travel, through an appropriate mix of uses. To enable access to services and make future communities in the area defined by ISPA4 sustainable, the policy should state the masterplanning of the site should also consider the inclusion of a local centre.
In order to enable access to services and make future communities in the area defined by ISPA4 sustainable, the policy should state the masterplanning of the site should also consider the inclusion of a local centre. This will also help to keep the plan more internally consistent e.g. with paragraph 6.17.
Object
Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft
Policy DM22 Car and Cycle Parking in New Development
Representation ID: 26584
Received: 02/03/2020
Respondent: Suffolk County Council
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The central parking core is defined in the IP1 area policies map. The West of the town centre (outside the core) has predominantly being for long stay parking (associated with offices/station). DM-22 states that no non-residential long stay car parks will be permitted. It is not clear whether this applies to the whole IP1 area or just the central parking area. The supporting text clarifies that it is for central parking core but to avoid inadvertently encouraging car use and increasing congestion, the control of the supply of additional long-stay spaces must be extended to the whole IP1 area.
The control of the supply of additional long-stay spaces must be extended to the whole IP1 area. Whilst there is some definition of operational parking through reference to staff parking not being included (para.9.22.8), examples of what would be included would provide a positive position. This could include spaces for deliveries, visitor spaces and potentially spaces for staff who use private transport for visiting clients for example. The county council would welcome the opportunity to discuss how the approach to operational and staff parking within the IP1 area could be effective.
Object
Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft
Policy DM4 Development and Flood Risk
Representation ID: 26593
Received: 02/03/2020
Respondent: Suffolk County Council
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
NPPF p.165 states “Major developments should incorporate sustainable drainage systems unless there is clear evidence that this would be inappropriate.” DM4a) states “... and wherever practicable appropriate application of Sustainable Drainage Systems (SuDS)”. Planning practice guidance paragraphs 082 and 083 uses the term “practicable” in reference deciding the most appropriate type, operation and maintenance of SUDS on a site, not the principle of using SUDS . The guidance makes a distinction between the terms "inappropriate” and “practicable”. The current wording of the policy is not consistent and could cause confusion. The words “where practicable” should be removed from the policy.
The words “where practicable” should be removed from the policy. The SFRA needs further work arising from Environment Agency data. SCC will assist the Borough in further developing this piece of evidence.
