Core Strategy and Policies Development Plan Document (DPD) Main Modifications

Object

Representation ID: 26770

Received: 23/09/2021

Respondent: Associated British Ports

Legally compliant? Not specified

Sound? 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. In that context, in our representations we noted 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. In our submission we requested the inclusion of additional wording in the final paragraph of Policy CS2
to be amended to “…and low elsewhere, unless otherwise agreed through masterplans and provided
that in all areas it does not compromise heritage assets.”.
We note that this has not been accounted for in the most recent Local Plan revision, and as noted in Policy IP037 above, the Island is still allocated for approximately 421 dwellings. ABP would like to note that this level of density on the Island will be difficult to achieve in viability terms, and instead a density of approximately 22 units per acre (circa. 200 units) will be more achievable to deliver a successful scheme. This density also does not match ABPorts vision for the Island Site which has been agreed with the Partners and the LEP.

Object

Representation ID: 26771

Received: 23/09/2021

Respondent: Associated British Ports

Legally compliant? Not specified

Sound? Not specified

The Port of Ipswich is situated both within and immediately adjoining the Waterfront area of IP-One. As well as maintaining its operational activities, ABPorts is concerned to ensure that it retains the right and ability to fully use its land and infrastructure for port purposes in the performance of its statutory duties and responsibilities as a harbour undertaking. The importance of the Port continuing to flourish as a major economic driver in the sub-region is recognised in the NALEP Strategic Economic Plan and in this Local Plan. ABPorts would wish to ensure that the Port’s 'significant (economic) role' and ability to expand further and assist in driving growth in the region is protected. ABPorts requests that recognition is made in Policy CS3 and its accompanying text to the Port and to other important existing employment and other activities within and adjoining the IP-One area which the Council wishes to safeguard and support.

Object

Representation ID: 26772

Received: 23/09/2021

Respondent: Associated British Ports

Legally compliant? Not specified

Sound? 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: 26773

Received: 23/09/2021

Respondent: Associated British Ports

ABPorts 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: 26774

Received: 23/09/2021

Respondent: Associated British Ports

ABPorts 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 ABPorts’ specific request for such reference in the previous Core Strategy and Policies Development Plan Document Review Preferred Options.

Support

Representation ID: 26775

Received: 23/09/2021

Respondent: Associated British Ports

ABPorts would like to see improvement of the junctions on the A14 around Ipswich in order to accommodate existing and future growth. ABPorts supports the efforts of IBC and SCC to lobby Highways England for such improvements and investigation of other potential improvements to the A14 and A12(S) corridors (this is referred to in the final paragraph of the consultation comments form in response to Policy CS20 & paras 8.222 - 8.225).

Object

Representation ID: 26776

Received: 23/09/2021

Respondent: Associated British Ports

Legally compliant? Not specified

Sound? Not specified

ABPorts 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: 26777

Received: 23/09/2021

Respondent: Associated British Ports

Legally compliant? Not specified

Sound? Not specified

Objects to reference in the section titled ‘Conservation Areas’ to 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” (last two bullet points). ABPorts benefits from ‘permitted development’ rights over land it owns which is classed as ‘operational land’ Part 17 is applicable to development by Statutory Undertakers. Reliance on its permitted development rights on its operational land within the Port estate (limited by environmental regulations and other considerations) is critical to the ability of ABPorts to fulfil its statutory duties. Therefore strongly resist any steps taken to seek to withdraw the permitted development rights it benefits from.

Support

Representation ID: 26778

Received: 23/09/2021

Respondent: Associated British Ports

ABPorts 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: 26779

Received: 23/09/2021

Respondent: Associated British Ports

ABPorts 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. We welcome the recognition at para 9.33.6 of the need for ABPort’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.