Ipswich Issues and Options for the Ipswich Local Plan Review, August 2017, Public Consultation Having reviewed the issues and options documents, the Society has made the following response: Part 1 Strategic / Cross Boundary Issues for Ipswich Borough Council and Suffolk Coastal District Council Q2: What are the advantages of your area that should be protected through local plans? A high quality historic environment rich in designated and non-designated heritage assets including listed buildings, conservation areas and parks and gardens. The Borough abuts the Suffolk Coasts and Heaths Area of Outstanding Natural Beauty, a nationally designated landscape, and impacts of development on the setting of which should be accorded full weight in the development plan. Q3: What are the disadvantages of your area that the local plans could try to address through the way land is used or developed? A number of brownfield sites along Star Lane and Grafton Way which interrupt the connectivity between the historic core of the town and the Waterfront. Environmental improvements to these important streets would facilitate the regeneration of the town. Q4: What are the key priorities you would like to be addressed by 2036 in the places across Ipswich and Suffolk Coastal where you live, work or study? Focus on the historic environment as a key driver for regeneration of the town s economy Q6: Which growth scenario should we plan for across the Ipswich Housing Market Area? SPS believes that the Baseline, Scenario A should be planned for. We believe that to aim for greater economic growth would require a substantial increase in the level of housing that would be undeliverable given the identified constraints on available housing land. Q13: Which distribution options do you think would be most appropriate to take forward? SPS considers that development should be concentrated within the town (Option 5) and an increase in density would be preferable to erosion of countryside edge locations or encroaching into adjoining districts. Failure to concentrate in large urban areas will mean
more greenfield sites need to be released which will reduce the viability of regeneration of urban brownfield sites. Q15: Should the spatial distribution of jobs growth align with housing growth or should we take a different approach which focuses on improving accessibility between homes and work places? To be truly sustainable SPS believes that jobs and homes should be proximate to minimise car journeys and safeguard the environment. Q17: Should the policy approach of maintaining the physical separation of villages from Ipswich be continued or should infill in gaps between settlements be considered a source of housing land? SPS would always seek to protect distinctive settlements and sensitive landscapes while recognising that in some instances sustainable locations should be brought forward in preference to encroaching into countryside. Q18: If development cannot be accommodated within Ipswich, should it be focused within the communities close to Ipswich or distributed within the larger Ipswich Housing Market Area? What criteria should guide its location? SPS would always seek to protect distinctive settlements and sensitive landscapes while recognising that in some instances sustainable locations should be brought forward in preference to encroaching into countryside. Q19: Should Ipswich switch employment land to housing use, even though the Borough has a high jobs target? Where should the Council prioritise protecting employment land? Small town centre employment sites which may represent a risk to residential amenity could be released for housing while accessible larger employment sites along the A14/A12 corridors should be protected. SPS believes that Baseline housing and economic growth which could allow surplus employment land to be released for housing. Q20: Is there other land within Ipswich Borough which should be considered for residential development? Is the approach to protecting open space the right one? SPS considers that open space in urban areas is valuable to well-being and residential amenity and should be protected.
Part 2 Issues and Options for Ipswich area only Q34: Do you consider any of the development management policies need to be amended? If so, which ones, why and how? DM5 Design. SPS notes that only criteria e and f refer to special townscape character and architectural quality but consider that to be inadequate to control the delivery of high quality design. Notwithstanding the supporting text we believe that the policy should be more specific and robust and refer you to SCDC Design Policy DM21 as a better example: Proposals that comprise poor visual design and layout, or otherwise seriously detract from the character of their surroundings will not be permitted. Development will be expected to establish a strong sense of place, using streetscenes and buildings to create attractive and comfortable places to live, work and visit. Accordingly, development will be permitted where the following criteria are met: (a) proposals should relate well to the scale and character of their surroundings particularly in terms of their siting, height, massing and form; (b) in areas of little or no varied townscape quality, the form, density and design of proposals should create a new composition and point of interest, which will provide a positive improvement in the standard of the built environment of the area generally; (c) alterations and extensions to existing buildings should normally respect the plan form, period, style, architectural characteristics and, where appropriate, the type and standard of detailing and finishes of the original building; (d) in order for extensions to existing buildings to be acceptable, particularly on those that are considered to be architecturally and historically important (including vernacular architecture) and those located in sensitive locations, the extension shall be visually recessive and its size and design shall be such that the original building will remain the more dominant feature on the site; (e) layouts should incorporate and protect existing site features of landscape, ecological, heritage or amenity value as well as enhance such features e.g. habitat creation; and (f) attention must be given to the form, scale, use, and landscape of the spaces between buildings and the boundary treatment of individual sites, particularly on the edge of settlements. SCDC DM21 DM34 Countryside criteria a and g are incompatible because a major housing development is unable to respect the character of the countryside which is defined by low density, sparse pattern of housing and open spaces. This policy also fails to specify a sequential approach to site selection, supporting brownfield before greenfield sites are released. Furthermore, the wording of the policy fails to include enhance when referring to council s statutory duty with regard to the AONB, in line with S.85 of the CROW Act. Q72: How can Ipswich continue to increase its offer as a tourist destination? SPS promotes investment in the historic environment as a major regeneration tool which in turn can be used to attract visitors.
Q79: What in your opinion makes a well-designed development? Do you feel that high quality design is being delivered in Ipswich? SPS considers that high quality design that creates a strong sense of place while contextually sensitive. While there are some examples of exceptional design in Ipswich (Willis Building) much of the recent residential development lacks distinction and makes at best, a neutral contribution to the identity of the town. Q80: Should Building for Life 12 continued to be used as a tool to improve the design quality of new development? SPS supports the use of Building for Life 12. Q81: Do you think the tall buildings around the Waterfront enhance the vibrancy of the area? Are there other areas of the town where additional tall buildings (of appropriate construction standards) would be appropriate? Yes. We support tall buildings (not exceeding 7 storeys) where they are of a very high standard of design and they do not cause harm to the setting of designated heritage assets. Q83: Do you feel there needs to be greater attention to the architectural design of buildings in these locations? We support the concept that gateway buildings should be of a very high standard of design however we would promote high standards of design in all sensitive townscape locations. Q84: What could be included in a positive strategy in the Local Plan to protect and enhance heritage assets? Policy DM8 lacks a positive statement setting out the approach of the management of the historic environment, for example: Development will not be permitted that will adversely affect a listed building, a conservation area, historic park or garden or important archaeological remains. Development affecting the historic environment should seek to preserve or enhance the heritage asset and any features of specific historic, archaeological, architectural or artistic interest. In all cases there will be an expectation that any new development will enhance the historic environment in the first instance, unless there are no identifiable opportunities available. In instances where existing features have a negative impact on the historic environment, as identified through character appraisals, the Local Planning Authority will request the removal of the features that undermine the historic environment as part of any proposed development. Support will be given to the provision of creative and accessible interpretations of heritage assets. Colchester Borough Council Policy DP14: Historic Environment Assets
Furthermore, a clear requirement for a Heritage Assessment should be included within the council s heritage policy in order to fully understand the significance of the asset and any changes impacting on it. Q85: Are the existing measures to control development in conservation areas effective, for example requesting that new shopfronts be constructed from high quality materials and respect the character and appearance of the building and street scene? Are there any other ways we can enhance conservation areas? The existing use of Article 4 Directions in conservation areas, together with appraisals and associated management plans, are appropriate measures but rely on regular review and strict application of the adopted guidance. Q89: How should the Waterfront be further developed as a heritage feature of the town? We support further development of the Waterfront where a very high standard of design is employed (not exceeding 7 storeys in this location) which does not harm the setting of designated heritage assets and better reveals their significance. Fiona Cairns MRTPI IHBC Director 24 October 2017