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Ipswich Local Plan

Proposed Submission Site Allocationsand Policies (Incorporating IP-One

Area Action Plan) DPD

Statement of Consultation(Proposed Submission – Regulation 19)

September 2015

Planning and DevelopmentIpswich Borough Council

Grafton House, Russell RoadIpswich IP1 2DE(01473) 432019

email: [email protected]

website: www.ipswich.gov.uk

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REPID

RESPONDENTNAME

SITE SUPPORT/OBJECT

REPRESENTATION SUMMARY CHANGE TO PLAN REQUESTED

5217 Historic England (MrTom Gilbert-Wooldridge) [243]

3.2 SUPPORT Our response to the Core Strategy Review seeksimprovements to the vision which would carryforward into this plan. We welcome the reference toObjective 8 under paragraph 3.2, as there is ageographical element to the protection andenhancement of the environment (including heritageassets) that needs to be addressed by this plan.


4.1 OBJECT There is sometimes a lack of detail and/or clarity interms of development constraints and issues in thesite sheets contained in Appendix 3. In particular,scheduled monument and archaeological issues arenot always properly addressed (see individual sites)in terms of what is required and the implications forpotential development schemes.

The status of the site sheets in Appendix 3 is notentirely clear. We consider that the individualallocation policies should refer to the need toobserve the site sheets in Appendix 3.

In order to make the plan sound, we recommend that all of thepolicies that allocate land for development (including SP2, SP5, SP6and SP7) contain the following wording before the table in eachpolicy:

"Development proposals should accord with the information set out inthe individual site sheets in Appendix 3"

5167 Ipswich Wildlife Group(Mr Steve Pritchard)[1164]

4.1 OBJECT Missing from the whole of part B - the relationship ofthese sites to the Ecological Network does notseem to have been considered.

EITHER include an assessment of the impact on the EcologicalNetwork under each site (stating 'None' if none)

OR Include a general statement saying that all allocations will besubject to assessment of impact on the Ecological Network.

5344 The KesgraveCovenant Ltd (MrCrispin Rope) [1439]

4.5 OBJECT Table 1 - Whilst we accept that meeting the fullhousing requirement is highly likely to necessitatejoint working with neighbouring areas, it isincumbent on Ipswich Borough Council to makebest use of land within its own boundary first beforeit relies on assistance from others. The evidencebase, in the form of the SHLAA, shows that it hasnot done that, because the SHLAA identifiesadditional opportunities within the Boroughboundary, including my client's land, which haspreviously been tested through and found to besuitable for housing.

Table 1 of the Site Allocations Plan should also be amended toinclude North-East Ipswich as per the representations above, and anyother post 2026 growth locations/allocations required.

5247 Environment Agency(Lizzie Griffiths)[1021]

4.9 OBJECT We support this policy and are pleased to notesome of our previous comments have been takenonboard, with reference made to the requirement forsite-specific Flood Risk Assessments to besubmitted in support of new development in FloodZones 2 and 3.We have had sight of the Council's Flood RiskSequential Test and Exception Test Statement, butthis document is not referenced within the DPD. Westrongly recommend this policy is amended,showing how you have had regard to the SequentialTest in the allocation of sites and include therequirement to apply the Exception test, asappropriate.

5460 Ipswich Central (MrPaul Clement) [1423]

5.13 OBJECT Section 5.13 (Page 40) - we disagree strongly thatthis is the only site available for retail development.Greater emphasis should also be placed uponfinding alternative uses for uneconomic andunderused retail units in secondary locations -primarily Carr Street (east) and Westgate Street(west) - and improvement to provision betweenTower Ramparts/Cornhill southwards.


5.16 SUPPORT Our 2014 consultation response noted that theWaterfront area forms part of the town's historicenvironment and contains a number of importantheritage assets including listed buildings and theWet Dock Conservation Area. It is an area that hasundergone much change in the past 15 years andcontinues to be identified for regenerationopportunities. Given the continued developmentopportunities and the importance of heritage assets,we sought greater reference to the historicenvironment. The additional wording in Paragraph5.16 (last two sentences) is welcomed.


5.2 OBJECT Support but require changes. We welcome theaddition of paragraphs relating to the historicenvironment (5.2, 57 and 5.8). This helps towardsmeeting Paragraph 126 of the NPPF which requiresLocal Plans to set out a positive strategy for thehistoric environment. The IP-One Area is ofconsiderable importance in terms of the historicenvironment, given that it contains the greatestconcentration of the town's designated heritageassets, with a number of important sites andopportunity areas.It will be important that area and site specificproposals adequately consider impacts on heritageassets (see separate representations).

It would be helpful if paragraph 5.8 referred to the national Heritage atRisk Register as well as the Council's approach to buildings at risk, asthe national register contains more than just listed buildings.

Proposed Submission Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document


5.4 OBJECT Section 5.4 (P38) - whilst the document states thatthe plan is consistent with the Masterplan andVision, there are substantial and important elementsthat are not consistent. The emphasis towards anorth-south progression (section 5.5 P38) is notconsistent with the planned retail development onthe Westgate area.

5298 Suffolk County Council(Mr Robert Feakes)[356]

5.41 OBJECT The County Council is content with policies SP15and SP16, however the supporting text could bemore accurate in respect of the Travel Ipswichprogramme. Paragraph 5.41 should be amended asfollows: 'Due for completion in 2015, it forms part ofa wider long term strategy to achieve a 15% switchto more sustainable modes, to enable Ipswich toaccommodate planned growth without acorresponding growth in congestion. This willinclude some further improvements to walkingroutes from the railway station ...'

Amend 5.41 to read: Travel Ipswich is a £21m package of measuresincluding traffic management and the promotion of smarter travelchoices such as bus, walking and cycling. Due for completion in 2015,it forms part of a wider long term strategy to achieve a 15% switch tomore sustainable modes, to enable Ipswich to accommodate plannedgrowth without a corresponding growth in congestion. This will includesome further improvements to walking routes from the railway stationvia Princes Street to the Central Shopping Area.


5.46 SUPPORT We note that the provision of a new Wet Dockcrossing would facilitate access and provide forthrough traffic, allowing for the calming of the StarLane Gyratory once completed. We support theprinciple of calming of the gyratory and theopportunities that provides. However, care willneed to be taken with regards to the design of thenew crossing, as it passes through the conservationarea. We welcome the inclusion of a new sentenceat the end of paragraph 5.46 which notes theconservation area and requires the crossing to takeaccount of heritage issues.


5.52 OBJECT Car Parking (section 5.52 P50) - we are notconvinced that Travel Ipswich has "encouragedmode switching" in the way described or aspired to.It may, instead, have simply reduced visitors whichis to the detriment of the town. We are extremelyconcerned about the way in which this sectionappears to indicate continuing with an anti-cardirection.


6.1 OBJECT We welcome the identification of opportunity areas.However, the identification of development optionsin each opportunity area does not alwayscorrespond with site allocations and often goesmuch beyond the boundaries of proposedallocations. This potentially creates some confusionand needs clarifying. While we welcome theidentification of development principles for eachopportunity area, this does not overcome the needfor the individual site sheets to contain specificdevelopment criteria. The key for each diagramshows listed buildings but not scheduledmonuments, which is not helpful in terms of clarity.

In order to make the plan sound, the key to each diagram shouldinclude scheduled monuments. Clarification should also be providedregarding the extent of development options against site allocations.


7.3 OBJECT Section 7.3 (P78) - we are disappointed andextremely surprised that neither Ipswich Central northe Greater Ipswich Partnership are viewed as 'keypartnerships' in helping to deliver any plans for thetown centre or beyond.


Appendix 3 -SiteAllocationDetails

OBJECT SCC appendices to the full representation set outadditional information relating to sites:Appendix 1: Potential developer contributionsAppendix 2: Indicative highway requirementsAppendix 3 (mis-labelled 2): Outline surface waterassessmentAppendix 5: amendments to the archaeologicalconstraints comments affecting certain sites.

Update site sheets.


IP004 - BusDepot, Sir AlfRamsey Way

OBJECT Allocation IP004 is in close proximity to permittedmineral and waste uses, which represent aconstraint on the development of this site. In linewith policies in the Minerals and Waste Plans andDM26 of the Ipswich Local Plan are likely to apply toensure that the new development is compatible withthat which is already permitted. If the design of newdevelopment at IP004 recognises these constraints,the allocation should prove deliverable.


IP005 -FormerTooksBakery, OldNorwichRoad

SUPPORT This site forms part of the approach to/from WhittonConservation Area and is likely to form part of itssetting. Development of 100 homes could have anotable impact on the conservation area, particularlyif Site IP032 was also developed for a similarnumber of homes along with Site 140b foremployment. We welcome the publication of adevelopment brief for this and the adjoining site(although we have not had sight of the brief) andthe requirement in the site sheet for development tohave regard to the conservation area.

5647 Ministry of Defence(Louise Dale) [1057]

IP005 -FormerTooksBakery, OldNorwichRoad

OBJECT Sites IP005, IP029, IP032, IP033,I P059a, IP061,IP105, IP140a and b, IP165, IP175, IP221, IP265and IP261. These referenced sites fall within the91.4m height consultation zone surroundingWattisham airfield. Therefore, any proposedstructures in these areas which may exceed 91.4mneed to be reviewed by this office.

5459 Boyer Planning (MrMatt Clarke) [293]

IP006 - CoOpWarehouse,Pauls Road

SUPPORT The East of England Co-operative Society supportthis proposed allocation for residentialredevelopment. The site is in a sustainable location,close to a wide range of facilities andservices, including shops, employment and publictransport, with access to the town centreand railway station.

5122 Co-op Juniors TheatreProductions Ltd (MrPaul Lofts) [1080]

IP006 - CoOpWarehouse,Pauls Road

OBJECT The current use as listed below does not include theuse made of the warehouse by the Co-op JuniorsTheatre Productions Ltd which has occupied part ofthe warehouse for over 25yrs. The Co-op Juniors isa charitable co-operative for the benefit of thecommunity providing young people with training indance, singing and stage craft. With a co-operativeethos the 'Juniors' provides young people with lowcost training to a very high standard ofperformance. This amateur group is probably thelargest in East Anglia.

Under Development constraints/issues.Need to relocate The Co-op Juniors to a building of suitable size andaccess.


IP010a - CoOp Depot,FelixstoweRoad

OBJECT The proposed allocation of this site for primarilyresidential use along with land for extension of theadjacent Rosehill Primary School is supported bythe East of England Co-operative Society. Toensure that the policy is effective and justified theland required for school expansion should be moreclearly substantiated. Exclusion of the southern partof land fronting Derby Road from the proposedallocation boundary is illogical and should bereinstated. A flexible approach to Section 106contribution requirements needs to be applied in thecontext of viability considerations and competingdemands from the site.

Include land fronting Derby Road (former car sales forecourt andgarage workshop) within site boundary.Define site area for school expansion based on quantifiedassessment of operational need.Refer to the need for flexible application of Section 106 requirementsin view of acknowledged constraints to ensure viability.



OBJECT The East of England Co-operative Societyconsiders that to ensure that the policy is effectiveand justified the land required for schoolexpansion should be more clearly substantiated.



OBJECT This document allocates land at FelixstoweRoad/Derby Road (site IP010a) for additionalprimary school provision. The allocation at IP010a isnecessary to enable expansion of the school. Theschool is already on a small site to meet demandarising from the housing growth planned in thevicinity of the school.

5113 Private Individual IP010a - CoOp Depot,FelixstoweRoad

OBJECT This plan seems to contain our premises 22 and22a Hines Rd. No one has contacted us about thisproposal which seems a bit remiss!Concord Video & Film Council.

The premises 22 and 22a Hines Rd should be excluded.

5347 Suffolk Wildlife Trust(Dr Simone Bullion)[1438]


OBJECT Support the principle of development on the site butrecommend that a reptile survey is undertaken priorto development.

Reptile survey required under constraints/ issues section


IP012 -Peter's IceCream

OBJECT The development constraints mentions the area ofarchaeological importance and the adjoining CentralConservation Area and Grade II* Church of StClement to the south. However, while the wordingexplains the implications for development in termsof archaeological matters, there is no explanation ofthe implications for development in terms of theconservation area and listed church. The lack ofclarity could affect proposals for this site. Othersites are clearer in terms of such matters (e.g.IP005).

In order to make the plan sound, there should be an additionalsentence after the current last sentence in the site sheet as follows:

"Development should have regard to the above heritage assets andconserve their significance"

5184 Parliament (Mr BenGummer) [1404]

IP015 - WestEnd RoadSurface CarPark

OBJECT A greater proportion of this land should be allocatedfor housing.

The site allocation should be amended.


IP029 - LandOpposite 674-734 BramfordRoad



IP029 - LandOpposite 674-734 BramfordRoad

OBJECT Recommend an ecological assessment and reptilesurvey prior to site clearance

Recommend an ecological assessment and reptile survey prior to siteclearance


IP031 -Burrell Road

OBJECT The development constraints mention the area ofarchaeological importance, the adjoining StokeConservation Area (a conservation area on theHeritage at Risk Register), and the Grade I Churchof St Mary at Stoke to the south. However, whilethe wording explains the implications fordevelopment in terms of archaeological matters,there is no explanation of the implications fordevelopment in terms of the conservation area andlisted church. The lack of clarity could affectproposals for this site. Other sites are clearer interms of such matters (e.g. IP005).

In order to make the plan sound, there should be an additionalsentence after the last sentence in the site sheet as follows:



IP031 -Burrell Road

SUPPORT The East of England Co-operative Society supportthis proposed allocation for residentialredevelopment.

5631 Private Individual IP031 -Burrell Road

OBJECT I wish to register an objection to the planningapplication to build 20 houses on the site.It will lead to an increase in traffic whilst at the sametime reducing the amount of parking available.Parking is already difficult in the area and the loss ofthe car park coupled with the parking needs of awhole new housing development will make it almostimpossible.The adjacent conservation area is likely to be put atrisk.A new development will be out of character in a partof the road that comprises older buildings.


IP032 - KingGeorge VField, OldNorwichRoad

SUPPORT As with Site IP005, this site falls within the setting ofWhitton Conservation Area and could affect itssignificance, with the risk of cumulative impact. Wewelcome the publication of a development brief forthis and the adjoining site (although we have nothad sight of the brief) and the requirement in thesite sheet for development to have regard to theconservation area.


IP032 - KingGeorge VField, OldNorwichRoad



IP033 - Landat BramfordRoad (Stockssite)



IP033 - Landat BramfordRoad (Stockssite)

OBJECT Recommend that a detailed ecological survey isundertaken as well as a reptile survey, but supportsthe need for a vegetation buffer around the pond.

Recommend that a detailed ecological survey is undertaken as wellas a reptile survey, but supports the need for a vegetation bufferaround the pond.


IP035 - KeyStreet / StarLane /Burtons Site

OBJECT This is a very sensitive site. It contains a Grade IIbuilding on College Street, adjoins the listed andscheduled Wolsey Gate and is located between twoconservation areas and two Grade II* churches. Interms of archaeology, there are two scheduledmonuments to the north while the site itself was thelocation of a priory&college.

The wording of the site sheet is not effective withregards to archaeological considerations. Thesheet should also be strengthened with regards toits wording on the conservation areas and listedbuildings, and better linked to national policywording.

In order to make the plan sound, the final three paragraphs of the sitesheet for IP035 should be amended along the following lines:"The site lies within the Area of Archaeological Importance, adjacentto the Grade I listed and scheduled Wolsey's Gate (List Entry Nos.1006071), between the Central and Wet Dock Conservation Areas,and contains a Grade II listed building. The Grade II* listed Churchesof St Peter and St Mary at the Quay lie on either side of the site. Anyproposals would need to consider the impact of development upondesignated and non-designated heritage assets and their setting,including any resulting benefit, harm or loss to their significance.Archaeological evaluations have revealed evidence of Anglo-Saxonoccupation and St. Peter's Priory and there is a high potential forarchaeological remains of possible national significance, such asimportant waterlogged remains and evidence Wolsey's College, and aQuaker Burial Ground.

Detailed early pre-application discussions with Suffolk County CouncilArchaeological Service and English Heritage [Historic England after1st April 2015] would be required in order to agree the principle ofdevelopment and inform design. Archaeology would be a majorconsideration for project costs and timescales. Proposals would needto be supported by programmes of pre-determination archaeologicalassessment. Total archaeological excavation of the site prior todevelopment would be required and preservation of archaeologicalevidence in situ may also be a consideration as part of mitigationmeasures. Post-excavation analysis, assessment and reportingwould also be necessary.

Proposals impacting the scheduled monument of Wolsey's Gate or itssetting would require detailed pre-application discussions with EnglishHeritage [Historic England after 1st April 2015]. Development couldpresent opportunities to enhance the significance of the scheduledmonument. Scheduled Monument Consent would be needed for anyworks upon or within the scheduled monument. The SMC applicationwould need to be accompanied by appropriate pre-applicationconsultation and assessment and where consent is granted,comprehensive archaeological mitigation is likely to be required.There is a presumption in favour of conserving scheduledmonuments, so the granting of consent is not guaranteed."

5387 Applekirk PropertiesLtd (Teresa Cook)[1452]

IP035 - KeyStreet / StarLane /Burtons Site

OBJECT The approach to proposals for retail development inthe Site Allocations Plan is at odds with theevidence base and crucially underplays the need toaccommodate retail growth in the town. ApplekirkProperties Ltd supports the allocation of sitesIP043, IP136, IP052 and IP035 for mixed usedevelopment that will contribute to the regenerationof the Waterfront/Merchant's Quarter, but objects tothe failure to provide for retail development inexcess of 200 sq m within these sites. Policies CS2,CS3 and CS5 fail to meet the requirement forcomparison retail identified in the evidence base.

Allocated sites within the Waterfront/Merchant's Quarter shouldprovide for a mix of residential and town centre uses including retail inexcess of 200 sqm floorspace, to allow flexibility to assemble a viabledevelopment scheme.


IP037 - IslandSite

SUPPORT The Island Site forms a large part of the Wet DockConservation Area and contributes to thesignificance of this heritage asset. We welcome thewording in the development constraints regardingthe retention and refurbishment of historicstructures and the reference to archaeologyincluding industrial heritage. The wording alsohelpfully refers to the principles contained withinOpportunity Area A (which we broadly support).


IP037 - IslandSite

OBJECT Allocation IP037 needs to recognise the mineralhandling facilities at the Port, which are protectedthrough the Minerals Plan and DM26 and are part ofthe delivery of a wider marine plan.


IP037 - IslandSite

OBJECT The emerging consensus from NALEP, SCC, UCSand the owner of the port is for employment use.IBC has been involved in these discussions.

The document should reflect existing aspirations for development.


IP039a -LandbetweenGower Street& Gt WhipStreet

OBJECT The development constraints refer to archaeologyand the adjoining listed building and conservationarea and refer to the development principlescontained within Opportunity Area A. However,while the wording explains the implications fordevelopment in terms of archaeological matters,there is no explanation of the implications fordevelopment in terms of the conservation area andlisted church. The lack of clarity could affectproposals for this site. Other sites are clearer interms of such matters (e.g. IP005).

In order to make the plan sound, there should be an additionalsentence after the second sentence in the development constraintssection of the site sheet as follows:



IP040 andIP041 - CivicCentre Area /Civic Drive

OBJECT The development constraints mention archaeology(if not the area of archaeological importance withcovers over half of the site), and the nearbyconservation areas and the Grade II* Church of StMatthew to the west. Reference is also made to thedevelopment principles contained within OpportunityArea E. However, while the wording explains theimplications for development in terms ofarchaeological matters, there is no explanation ofthe implications for development in terms of theconservation areas and listed church. The lack ofclarity could affect proposals for this site.

In order to make the plan sound, there should be an additionalsentence after the final sentence of the site sheet as follows:


5206 The Theatres Trust(Planning Adviser)[278]


OBJECT Support but require changes. The adjacent theatreshould be noted as a constraint to ensure thatnoise, vibration and access issues are consideredin the design.



OBJECT The primary allocation for this site should beresidential - especially for sheltered and verysheltered accommodation. This reflects theaspirations for the town centre from Ipswich Centraland SCC.

Use allocation should be changed.



OBJECT Site IP040 and IP041 - this site should not beallocated for retail, but for primarily residentialdevelopment.

5586 Ipswich ConservativeGroup [1814]


OBJECT IP040 and IP041 Civic Centre Area - this shouldnot be designated as mainly a retail area and webelieve that a shrinking of the town centre, bymaking both ends a mix of homes and smallindependent shops, as well as leisure facilities,would create footfall in the town centre and be amore attractive experience for shoppers.


IP043 -CommercialBuildings andJewish BurialGround, StarLane

OBJECT This is a very sensitive site partly within the CentralConservation Area and containing Grade II listedbuildings while adjoining other listed buildings. Thearchaeological issues include the Jewish BurialGround.

Although the revised site sheet now refers to manyof the above heritage assets, the wording is noteffective with regards to archaeologicalconsideration. The revised site sheet should alsobe strengthened with regards to its wording on theconservation area and listed buildings, and betterlinked to national policy wording. Clarity is alsoneeded regarding the burial ground.

In order to make the plan sound, the final paragraph of the site sheetfor IP043 should be replaced along the following lines:

Any proposals would need to consider the impact of developmentupon designated and non-designated heritage assets and theirsetting, including any resulting benefit, harm or loss to theirsignificance. The site presents opportunities for enhancing theJewish Burial Ground, which needs to be carefully respected by anydevelopment proposal. Archaeological evaluations and limitedexcavation have revealed evidence of Anglo-Saxon and medievalactivity (there is outstanding post-excavation work underIP/11/00267). Detailed early pre-application discussions with SuffolkCounty Council Archaeological Service and English Heritage [HistoricEngland after 1st April 2015] would be required in order to agree theprinciple of development and inform design. Archaeology would be amajor consideration for project costs and timescales.

Proposals would need to be supported by programmes of pre-determination archaeological assessment and possibly evaluation.Complex archaeological mitigation is likely to be required which couldinclude watching briefs, full excavation and / or design schemechanges to allow for preservation in situ. Post-excavation analysis,assessment and reporting would also be necessary."


IP043 -CommercialBuildings andJewish BurialGround, StarLane




IP048 - MintQuarter / CoxLane

OBJECT This is a very sensitive site, where approximatelyhalf of the site is designated as a scheduledmonument and there is considerable archaeologicalpotential across the whole site. The site alsoadjoins the conservation area and listed buildings.

Although the revised site sheet now refers to theabove heritage assets the wording is not effectivewith regards to archaeological considerations,particularly with regards to the scheduledmonument. The revised site sheet should also bestrengthened with regards to its wording on theconservation areas and listed church, and betterlinked to national policy wording.

In order to make the plan sound, two amendments are required to thesite sheet for IP048. There should be three new sentences at the endof the second paragraph of the development constraints section asfollows:"Approximately half of the site is designated as a scheduledmonument (List Entry No. 1005983) and represents a large portion ofthe Anglo-Saxon and medieval town preserved under car parks.Excavations and interventions have taken place in parts of the siteand revealed evidence for occupation and activity from the MiddleSaxon period onwards; the rest of the site is undisturbed from moderndevelopment and is anticipated to contain rich and well preservedarchaeological remains. Any proposals would need to consider theimpact of development upon designated and non-designated heritageassets and their setting, including any resulting benefit, harm or lossto their significance."

The final paragraph should be replaced along the following lines:"There is a high potential for archaeological remains of nationalsignificance and detailed early pre-application discussions with SuffolkCounty Council Archaeological Service and English Heritage [HistoricEngland after 1st April 2015] would be required in order to agree theprinciple of development and inform design. Archaeology would be amajor consideration for project costs and timescales. Proposals wouldneed to be supported by programmes of pre-determinationarchaeological works which may include desk-based assessments,historic building analysis, survey works and archaeological evaluation.Complex archaeological mitigation is likely to be required which couldinclude watching briefs, full excavation and / or design schemechanges to allow for preservation in situ. Post-excavation analysis,assessment and reporting would also be necessary.

Scheduled Monument Consent (SMC) would be needed for any workswithin the Scheduled Monuments. The SMC application would needto be accompanied by appropriate pre-application consultation andassessment (with English Heritage) and where consent is granted,comprehensive archaeological mitigation is likely to be required. Thereis a presumption in favour of conserving scheduled monuments, sothe granting of consent is not guaranteed."



OBJECT The East of England Co-operative Society supportredevelopment of the Mint Quarter. It is consideredthat an element of flexibility should be applied to themix of uses that would be considered acceptable inthis area, in order to maximise the potential forachievement of regeneration of this important site.Such flexibility should also extend to the façade ofparts of the former Co-operative department storefrontage to Carr Street, following inclusion in theLocal List SPD.

To ensure this policy is both justified and effective reference shouldbe made to a flexible approach the mix of uses consideredacceptable.In respect of the facade of part of the former Co-operative departmentstore frontage to Carr Street reference to this being retained shouldeither be qualified by further assertions that loss would potentially beconsidered in the context of a high quality design solution, or in lightof viability considerations, or alternatively reference to retentionshould be deleted completely, being adequately addressed within theLocal List SPD itself.



OBJECT Site IP048 - the area of this site that sits closest toUpper Brook Street should be allocated for amodern 'big-box' retail cluster. We envisagesomething like an out-of-town retail developmentwith parking, built on this in-town site.


IP052 - LandbetweenLower OrwellStreet & StarLane

OBJECT The development constraints mention the area ofarchaeological importance, the adjoining CentralConservation Area and nearby scheduledmonuments, but only refers to the Grade II* listedbuilding to the north when there is also a Grade IIbuilding (26-28 Fore Street). While the wordingexplains the implications for development in termsof archaeological matters, there is no explanation ofthe implications for development in terms of theconservation areas and listed buildings. The lack ofclarity could affect proposals for this site. Othersites are clearer in terms of such matters (e.g.IP005).

In order to make the plan sound, there should be an additionalsentence after the current last sentence of the site sheet as follows:


The first sentence of the site sheet should refer to the Grade II listedbuilding, while the ID numbers used for the scheduled monumentsshould use the modern list entry numbers for clarity (Nos. 1005985,1002973, 1005986).


IP052 - LandbetweenLower OrwellStreet & StarLane




IP054 - Landbetween OldCattle Marketand StarLane

OBJECT This is a very sensitive site partly within theconservation area and containing two Grade IIbuildings and two scheduled monuments withconsiderable archaeological potential across thesite. The site is flanked by the conservation areaand several listed buildings, with two Grade II*churches to the south.

Although the revised site sheet now refers to someof the above heritage assets, the wording is noteffective with regards to archaeologicalconsiderations. The revised site sheet should alsobe strengthened with regards to its wording on theconservation areas and listed buildings, and betterlinked to national policy wording.

In order to make the plan sound, the final paragraph of the site sheetfor IP043 should be replaced along the following lines:"The site lies within the Area of Archaeological Importance, partlywithin the Central Conservation Area, contains and adjoins listedbuildings and includes a Scheduled Monument (List Entry No.1005987), which is split into two separate areas. Any proposalswould need to consider the impact of the development upon thedesignated and non-designated heritage assets and their setting,including any resulting benefit, harm or loss to their significance. Theroute of Turret Lane should be protected.Previous archaeological works have demonstrated strong evidencefor well-preserved of waterlogged and organic deposits and there is ahigh potential for archaeological remains of national significance.Detailed early pre-application discussions with Suffolk County CouncilArchaeological Service and English Heritage [Historic England after1st April 2015] would be required in order to agree the principle ofdevelopment and inform design. Archaeology would be a majorconsideration for project costs and timescales.

Proposals would need to be supported by programmes of pre-determination archaeological works which may include desk-basedassessments, survey works and archaeological evaluation. Complexarchaeological mitigation is likely to be required which could includewatching briefs, full excavation and / or design scheme changes toallow for preservation in situ. Post-excavation analysis, assessmentand reporting would also be necessary.

Scheduled Monument Consent (SMC) would be needed for any workswithin the Scheduled Monuments. The SMC application would needto be accompanied by appropriate pre-application consultation andassessment (with English Heritage) and where consent is granted,comprehensive archaeological mitigation is likely to be required. Thereis a presumption in favour of conserving scheduled monuments, sothe granting of consent is not guaranteed."

The archaeological potential of this site could greatly influence itsredevelopment (bearing in mind that archaeology could extendbeyond the scheduled areas). Including the scheduled monumentswithin the site without any recognition or development criteriaincreases the risk of proposals that directly or indirectly harm theirsignificance.

5123 Private Individual IP054 - Landbetween OldCattle Marketand StarLane

SUPPORT We believe the Local Plan is of sound judgementand agree with what has been proposed.


IP055 -Crown CarPark, CharlesStreet

OBJECT IBC should retain the option of an allocation forhousing or mixed development, should they be ableto relocate the car park to south of Crown Street.

Greater flexibility in this allocation.

5436 Anglian Water (SueBull) [359]

IP058 -Former VolvoSite, RaeburnRoad South

OBJECT Relating to the proposed sites located in proximity tothe Water Recycling Centres- WRCs (formallyreferred to as Sewage or Wastewater TreatmentWorks), -although reference is made in the text totheir location in relation to the WRC, it isrecommended that there is a requirement that anodour assessment (in liaison with the WRCoperator) is carried out to assess the risk of odourimpact on the proposed development to ascertainthe suitability of the site for residential development.The sites are IP058 IP067 and IP099


IP058 -Former VolvoSite, RaeburnRoad South

OBJECT This site is currently a County Wildlife Site adetailed survey will need to be undertaken prior todevelopment.

This site is currently a County Wildlife Site a detailed survey will needto be undertaken prior to development.


IP059a -Elton ParkIndustrialEstate,HadleighRoad


5628 Private Individual IP061 -FormerSchool Site,LavenhamRoad

OBJECT It would become a slum area - houses/flats on topof each other; it would be cramming houses/flatsinto such a small area which draws a fine linebetween planning and cramming;noise pollution; we are very quiet whereas with anextension of houses, we would loose our peace andtranquillity;overlooking existing properties, therefore invadingtheir privacy and lost of their natural light;there are plenty of boarded uphouses/factories/empty offices along Hadleigh Road- why are they not being used for housing?


OBJECT The green is a strong local asset which allowsresidents to meet regularly. The development of thegreen will have a detrimental effect on housevalues, lead to loss of light to existing property,exacerbate existing parking, traffic flow and roadsafety issues, and lead to loss of wildlife habitat.Concern that the consultation was not adequatelyadvertised.


OBJECT The Green is an area for the local community.Children play football there and there are manycommunity and sporting events. Concerned aboutanti-social behaviour if the green is taken away. Itwas reported in the press that the Council weretrying to improve the area for youngsters, why takeall this away? Concern expressed about existingand potential problems of parked cars and roadsafety in the Lavenham Road and Kelly Road area.The Green is lovely to look at and enjoy and shouldbe preserved.


OBJECT We object to the proposed building of houses onthis area. The area needs a suitable place forchildren to play safely, residents to walk their dogsand an area where the local community cansocialise.This area if utilised properly could be the hub of thisarea, bringing all residents together. These dayspeople complain that their children need to get outmore; this area is an ideal area for this to happen ifit is kept as an open green space, and as previouslystated this would be an ideal area for the outsideGym and Play Area.


OBJECT I cannot believe that this may still be passed as Ifeel that not only will added traffic going through thisquiet road be dangerous but especially in winterwhen Lavenham Road hill is already a hazard in icyconditions with cars etc unable to get up the hill ashardly ever gritted and my property at the bottom ofthe hill is just another accident waiting to happenAGAIN!When we bought our first house in Milden Roadwhich was a new build, we were told that the greenwould never be built on.


OBJECT The Green is currently a nice open space used byyoungsters and for fetes and football. Do not wish tobe overlooked and surrounded by more houses.The open space is lovely and well kept, not aderelict building site.


OBJECT The roads in Lavenham Road are not wide enoughto cater for more cars, the dust carts can't evenaccess roads when cars are parked on it. Also therearen't enough green/natural areas in the area sowhy do you need to take more away from thecommunity.


IP061 -FormerSchool Site,LavenhamRoad



OBJECT Object to development of this land as it is an openarea used for community events, dog walking, andby children playing. There is already parkingcongestion and this will add additional pressure.Understood the land could only be used for buildinga school.


OBJECT I am writing to object to the proposed plans forbuilding on the green between Lavenham and KellyRoad. My fiancée and I are new residents toLavenham Road as we bought our house inDecember and we are extremely upset to hear thatthere are plans to build on the green.


OBJECT Wish to object to the proposed allocation as theGreen is used by local children to play football andcricket, children feel safer playing there than out ofsight in the park, the Green is used by the localchurch for fun days and concerned about theincrease in traffic on the narrow road.


OBJECT The green is a strong local asset which allowsresidents to meet regularly. The development of thegreen will have a detrimental effect on housevalues, lead to loss of light to existing property,exacerbate existing parking, traffic flow and roadsafety issues, and lead to loss of wildlife habitat.Concern that the consultation was not adequatelyadvertised.


OBJECT Concerned about increases in traffic and concernedabout anti-social behaviour including speedingvehicles. Believe there is sufficient social housing inthe area. Would not like to see Lavenham Roadjoined with Kelly Road.


IP067 -FormerBritish EnergySite

OBJECT Relating to the proposed sites located in proximity tothe Water Recycling Centres- WRCs (formallyreferred to as Sewage or Wastewater TreatmentWorks), - although reference is made in the text totheir location in relation to the WRC, it isrecommended that there is a requirement that anodour assessment (in liaison with the WRCoperator) is carried out to assess the risk of odourimpact on the proposed development to ascertainthe suitability of the site for residential development.The sites are IP058 IP067 and IP099



OBJECT Recommend an ecological survey prior tovegetation clearance.

Recommend an ecological survey prior to vegetation clearance.

24213 EDF Energy Plc (MissNicola Forster) [248]


OBJECT Pleased that the site has been allocated fordevelopment. Housing could be accommodated inthe northern part with employment on the southernpart and a buffer in the middle. The NPPF statesthat planning policies should avoid long termprotection of allocated employment sites wherethere is no reasonable prospect of the site beingused for that purpose. It is not feasible to allocatethe site for 100% employment. There has beenprevious interest from residential developers. Thesite can be configured to offset impacts of the watertreatment works. The site boundary should reflectland ownership arrangements.

The allocation should include an element of housing and the siteboundary should be amended to land ownership arrangements.


IP080 - 240WhersteadRoad

OBJECT Site IP080 needs to recognise the mineral handlingfacilities at the Port, which are protected through theMinerals Plan and DM26 and are part of the deliveryof a wider marine plan


IP083 -Banks of riverupriver fromPrincesStreet

OBJECT This area is allocated for public open space and wesupport the requirement for survey work prior toclearance, as well as retaining the river path and itssetting, the design must take into account the needto avoid light spillage within the river corridor.

This area is allocated for public open space and we support therequirement for survey work prior to clearance, as well as retainingthe river path and its setting, the design must take into account theneed to avoid light spillage within the river corridor.


IP089 -WaterworksStreet

OBJECT The development constraints mention the area ofarchaeological importance, the part location withinthe (Central) conservation area and adjacent listedbuilding (although there is more than one listedbuilding in the vicinity). However, while the wordingexplains the implications for development in termsof archaeological matters, there is no explanation ofthe implications for development in terms of theconservation area and listed buildings. The lack ofclarity could affect proposals for this site. Othersites are clearer in terms of such matters (e.g.IP005).



The first sentence of the development constraints section shouldclarify that the site is adjacent to listed buildings (not just the one).


IP089 -WaterworksStreet

SUPPORT Support allocation


IP096 - CarParkHandfordRoad East

OBJECT The development constraints mention archaeologyand the adjoining (Burlington Road) conservationarea. However, while the wording explains theimplications for development in terms ofarchaeological matters, there is no explanation ofthe implications for development in terms of theconservation area. The lack of clarity could affectproposals for this site. Other sites are clearer interms of such matters (e.g. IP005).

In order to make the plan sound, there should be an additionalsentence before the last sentence of the first paragraph in thedevelopment constraints section of the site sheet as follows:

"Development should have regard to the conservation area and otherheritage assets and conserve their significance"

5528 RCP Parking Ltd[1418]

IP096 - CarParkHandfordRoad East

OBJECT RCP Parking Ltd support the allocation of their sitein principle for residential purposes but the decisionof when to develop/dispose should be part of theircommercial strategy rather than the council isplanning authority or a third party. The draftallocation indicates that has a short term deliverytimescale but the company has not been consultedon its own business plans. Had it been so consultedit would have reaffirmed the need for flexibility andthe certainty of interim beneficial uses such asshortstay car parking in a continuing difficulteconomic climate.

There is a need for greater flexibility either within the specific wordingof SP2 to facilitate interim alternative uses until the viability/returns ofthe alternative use of the land for residential development fits withinthe site owners business strategy.


IP098 -Transco,south ofPattesonRoad



IP099 - Partformer VolvoSite, RaeburnRoad South

OBJECT Relating to the proposed sites located in proximity tothe Water Recycling Centres- WRCs ( formallyreferred to as Sewage or Wastewater TreatmentWorks), - although reference is made in the text totheir location in relation to the WRC, it isrecommended that there is a requirement that anodour assessment ( in liaison with the WRCoperator) is carried out to assess the risk of odourimpact on the proposed development to ascertainthe suitability of the site for residential development.The sites are IP058 IP067 and IP099


IP105 -Depot,BeaconsfieldRoad


5761 Private Individual IP116 - StClement'sHospitalGrounds

OBJECT Site has injunction on it to prevent any other useother than for mental health.


IP11b - SmartStreet,FoundationStreet

OBJECT This is a very sensitive site. In particular, the sitecontains three scheduled monuments, withconsiderable archaeological potential across thesite. The site also adjoins the Central and WetDock Conservation Area, along with the Grade II*Church of St Mary at the Quay.

Although the revised site sheet now refers to theabove heritage assets, the wording is not effectivewith regards to archaeological considerations. Therevised site sheet should also be strengthened withregards to its wording on the conservation areasand listed church, and better linked to nationalpolicy wording.

In order to make the plan sound, the final two paragraphs of the sitesheet for IP011b should be amended along the following lines:"The site lies within the Area of Archaeological Importance, includesthree scheduled monuments (List Entry Nos. 1005985, 1002973,1005986) and is located adjacent to the Central and West DockConservation Areas with the Grade II* Church of St Mary at the Quayto the south. Any proposals would need to consider the impact ofdevelopment upon designated and non-designated heritage assetsand their setting, including any resulting benefit, harm or loss to theirsignificance.There is a high potential for archaeological remains of nationalsignificance and detailed early pre-application discussions with SuffolkCounty Council Archaeological Service and English Heritage [HistoricEngland after 1st April 2015] would be required in order to agree theprinciple of development and inform design.

Archaeology would be a major consideration for project costs andtimescales. Proposals would need to be supported by programmes ofpre-determination archaeological works which may include desk-based assessments, survey works and archaeological evaluation.Complex archaeological mitigation is likely to be required which couldinclude watching briefs, full excavation and / or design schemechanges to allow for preservation in situ. Post-excavation analysis,assessment and reporting would also be necessary.Scheduled Monument Consent (SMC) would be needed for any workswithin the Scheduled Monuments. The SMC application would needto be accompanied by appropriate pre-application consultation andassessment (with English Heritage) and where consent is granted,comprehensive archaeological mitigation is likely to be required. Thereis a presumption in favour of conserving scheduled monuments, sothe granting of consent is not guaranteed."


IP133 - Southof FelawStreet

OBJECT We note this site is now proposed for allocationfollowing the lapse of planning permission. The siteadjoins the Wet Dock Conservation Area and theGrade II listed building of 42-48 Felaw Street, and iswithin the area of archaeological importance. Whilethe development constrains refer to the area ofarchaeological importance, there is no reference tothe conservation area or listed building, or what theimplications are for development. The lack of claritycould affect proposals for this site, notwithstandingthe reference to the development principles set outin Opportunity Area A.

In order to make the plan sound, the development constraints sectionof the site sheet should refer to the conservation area and listedbuilding, and state that "development should have regard to heritageassets and conserve their significance". Clarification of thearchaeology issues should also be included.


IP133 - Southof FelawStreet


5126 Private Individual IP133 - Southof FelawStreet

OBJECT Given the number of identified brown field sites inthe consultation document, the development of 33houses on this site is an unnecessary conversationof a green space into a built environment. This isthe only area of green land available to children inthe area and is used by adults and children forrecreational purposes. There is a high density ofhousing around the space, with a young populationand no other available recreational area nearby,within walking distance available to children. Thecouncil should reconsider the allocation of anybuilding on this land.

Retain it as green space not suitable for development

5127 Private Individual IP133 - Southof FelawStreet

OBJECT Given the number of identified brown field sites inthe consultation document, the development of 33houses on this site is an unnecessary conversationof a green space into a built environment. This isthe only area of green land available to children inthe area and is used by adults and children forrecreational purposes. There is a high density ofhousing around the space, with a young populationand no other available recreational area nearby,within walking distance available to children. Thecouncil should reconsider the allocation of anybuilding on this land

If the number of dwellings was significantly reduced with a greenspace included as central to the development - this would bebeneficial to the new and existing families in the area.

Perhaps a nice "green" or eco development, with living walls, veryenergy efficient, lovely green space and SUDS to allow grass to growand cars to park.


IP136 - Silo,CollegeStreet

OBJECT IP136: College StreetThis is a sensitive site within the Central and WestDock Conservation Areas and opposite the Grade Ilisted and scheduled Wolsey Gate, plus sits withinthe area of archaeological importance. Thedevelopment constraints mention these heritageassets, but apart from archaeology, there is noexplanation of the implications for specific proposalswith regards to the conservation area andlisted/scheduled gate. The lack of clarity couldaffect proposals for this site. Other sites are clearerin terms of such matters (e.g. IP005).




IP136 - Silo,CollegeStreet




IP140 - LandNorth ofWhitton Lane

OBJECT As with Sites IP005 and IP032, this site falls withinthe setting of Whitton Conservation Area and couldaffect its significance, with the risk of cumulativeimpact. The conservation area is not mentioned inthe development constraints (although archaeologyis). The lack of clarity could affect proposals forthis site, and is not consistent with the wording usedin the site sheets for IP005 and IP032.

In order to make the plan sound, the development constraints sectionof the site sheet should refer to the conservation area, and state that"development should have regard to the conservation area andconserve its significance".




5615 Ashfield Land Limited(Mr Paul Derry) [1122]


SUPPORT Ashfield Land supports the identification of the site'Land North of Whitton Lane' Site ref IP140 (UC257)for employment development. The site isstrategically located within the Ipswich Policy Areabeside the A14 and adjoins the existing Anglia Parkemployment area.

5703 Private Individual IP140 - LandNorth ofWhitton Lane

OBJECT Object to the allocation of this greenfield site. Thereare considerable 'brown field' sites standing idle e.g.the sugar beet factory in Sproughton, HadleighRoad Industrial site, etc. Power lines and a gaspipeline cross the site. Development would have asignificant visual impact on the area. There isalready congestion so significant new infrastructurewould be needed. Development would impact onwildlife and protected species including badgers andslow worms, pollute the air and land, harm Whittonconservation area and destroy pathways. The landhas significant drainage issues and includesmedieval hedgerows. Claydon and Whitton will losetheir identity.









OBJECT This site might be needed as one of the options fora northern route.

Allowance made.


OBJECT The potential change and the development seemsbadly conceived, serving the interests of thedeveloper but no-one else. Our green spaces needto be protected not destroyed.





5115 RavenswoodResidents Association

IP150b(UC267 part) -Land south ofRavenswood

OBJECT Road access and egress to and from Ravenswoodis a growing problem. We will want to be satisfiedthat this development has new and adequate roadaccess and that the opportunity is taken to relievepressure on the single access point that currentlyexists.As the Residents Association we wish to participatein early consultation and to be kept informed ofprogress of the site development proposal ingeneral and any specific plans in particular.

To incorporate improved road access to Ravenswood


IP150c(UC267) -Land SouthofRavenswood


To improve road access to Ravenswood


IP152 -Airport FarmKennels,North of theA14


To improve road access to Ravenswood


IP165 -EastwayBusinessPark, EuropaWay



IP172 - 15-19St Margaret'sGreen

OBJECT The development constraints mention the site'slocation within the Central Conservation Area andarea of archaeological importance and the nearbylisted buildings and scheduled monument.However, while the wording explains theimplications for development in terms ofarchaeological matters, there is no explanation ofthe implications for development in terms of theconservation area and listed buildings. The lack ofclarity could affect proposals for this site. Othersites are clearer in terms of such matters (e.g.IP005).




IP188 -WebstersSaleyard site,Dock Street

OBJECT The development constraints mention the site'slocation within the Stoke Conservation Area(currently on the Heritage at Risk Register) and areaof archaeological importance and the nearby listedbuilding. However, while the wording explains theimplications for development in terms ofarchaeological matters, there is no explanation ofthe implications for development in terms of theconservation area and listed building. The lack ofclarity could affect proposals for this site. Othersites are clearer in terms of such matters (e.g.IP005).




IP221 - FlyingHorse PH, 4WaterfordRoad


5518 Sports England (MrPhilip Raiswell) [290]

IP256 -Artificialhockey pitch,IpswichSports Club

OBJECT No objection provided the supporting text clearlyindicates the need for quantitative or qualitativereplacement provision, depending on the findings ofthe Playing Pitch Strategy currently being carriedout by Ipswich Borough Council.

5825 Private Individual IP256 -Artificialhockey pitch,IpswichSports Club

OBJECT Access is limited and not suitable for the volume oftraffic development would create, the hockey pitchhas been well used and we should not reducecommunity facilities.


OBJECT Pleased to note that the number of dwellings hasbeen reduced to 18. However, the density is out ofcharacter with the area and a lower density shouldbe recommended. The development would diminishthe effective use and potential for sport in the localarea. It is important to encourage local facilities,especially when considering the effect of trafficrelated to the planned Northern Fringedevelopment.

5601 House of Commons(MP Dan Poulter)[1170]


OBJECT Understand that Ipswich Sports Club has applied toIpswich Borough Council for the land that theartificial grass hockey pitch sits on to be included inthe local plan for building, in order to increase itsleisure facilities and create a 'hockey-hub'. I alsounderstand that Ipswich Borough Council areconducting a strategic review of sports facilitieswhich is due to be completed in March/April 2015.Wish to support Ipswich Sports Club and ask theCouncil to consider the development of their sportsfacilities in the strategic review.


OBJECT I object to this proposal the site area of the hockeypitch is not 0.87 but in fact 0.80 as the former figureincludes the access road to the club. the hockeypitch has been well used since 1952 and with thedevelopment of 3500 homes on the Northern fringethe retention of this sporting facility is important forhealth of residents and feel confident will thrive andprosper. Once this land is lost there will be nowherefor the club to grow. if allocated the maximumdensity should be 12 units in keeping withsurrounding area.

Reduction in density to 12 should it be allocated.


OBJECT I object to the inclusion of site ref IP256 for thefollowing reasons:- site has drainage problems- access to Henley Road is inadequate- density is completely out of keeping with thesurrounding area

Delete

5533 Ipswich Sports Club[1417]


SUPPORT Support the allocation of land for residentialdevelopment and confirm that the site is availableand deliverable now.

Remove the need to retain a facility for recreational requirements


OBJECT The access is limited and not suitable for thevolume of traffic the development would create, thehockey pitch is a well used community facility.


IP258 - Landat UniversityCampusSuffolk

OBJECT The development constraints mention the adjoiningconservation area and archaeology issues, but donot refer to the Grade II listed Church of Holy Trinityto the south. However, while the wording explainsthe implications for development in terms ofarchaeological matters, there is no explanation ofthe implications for development in terms of theconservation area and listed building. The lack ofclarity could affect proposals for this site. Othersites are clearer in terms of such matters (e.g.IP005).



The listed church should be mentioned in the first paragraph of thedevelopment constraints section.


IP258 - Landat UniversityCampusSuffolk

OBJECT This document allocates land at the University (siteIP258) for additional primary school provision. SiteIP258 is not deliverable for the purposes of PolicyCS15 or for mitigating the impact of Town CentreHousing sites. The County Council is consideringother options for making suitable primary schoolprovision for demand arising from the Town Centreand intends to have identified another deliverableoption by the time of the examination.

5243 Associated BritishPorts [209]

OpportunityArea A -Island Site

OBJECT ABP supports the identification of the Island Site asan opportunity area, and generally supports thepoints set out under 'Development Opportunities'and 'Development Principles'. However, ABPrequests the removal of reference to "lower risedevelopment" in the supporting text and to"generally low to medium rise development (3, 4 and5 storeys)" to allow more flexibility in thedevelopment of a viable scheme capable ofaddressing the particular development costs on thissite. ABP also requests the removal of "(max 50%)"against the residential reference, allowing a moreflexible proportion of acceptable uses.

ABP requests the removal of reference to "lower rise development" inthe supporting text and to "generally low to medium rise development(3, 4 and 5 storeys)" to allow more flexibility in the development of aviable scheme capable of addressing the particular developmentcosts on this site. ABP also requests the removal of "(max 50%)"against the residential reference, allowing a more flexible proportion ofacceptable uses.



OBJECT Support but require changes. This opportunity areais relatively coherent in terms of the sites it coversalong the waterfront. References to the historicenvironment are good, including consideration ofarchaeology issues. We welcome statements suchas maintaining the character of the conservationarea and the retention of historic structures. Thetwo diagrams show a number of non-listed buildingsin bold outline. The key does not explain whatthese denote, but it appears to relate to retainedbuildings. This should be clarified.



OBJECT Island Site (P56) - we are encouraged by the'Enterprise Island' plans, particularly if an integratedtransport improvement is included. The plans mostrecently revealed go further than the DevelopmentPlan suggests.


OpportunityArea B -MerchantQuarter

OBJECT This is a more complex and diverse area than AreaA, and perhaps less coherent making it difficult toestablish specific development principles relating tospecific sites. Current references to the historicenvironment are welcomed, but there needs to begreater detail with regards to scheduled monumentsand archaeology given the rich potential of thisarea. Scheduled monuments are not shown ineither diagram, with 'development options' mappedover the top of every scheduled monument withinthis area. This is misleading and does not providesufficient clarity for development proposals.

In order to make the plan sound, the two diagrams for Area B shouldshow the extent of the area's scheduled monuments. Given theuncertainty regarding the full extent of archaeology within this part ofIpswich, we do not require the 'development options' shading to bemodified, but the text before the table of developmentopportunities/principles should clarify that the full extent ofdevelopment will be subject to archaeological evaluation. We alsoconsider that the bullet point relating to scheduled monuments andarchaeology in the development principles column should beamended and strengthened along the lines of "development toaddress and conserve scheduled monuments and archaeology".



SUPPORT Merchant Quarter (P62) - we are broadly supportiveof a mixed residential, retail and restaurant/cafédevelopment. Car parking should be included, ifpossible.



OBJECT The Opportunity Area guidance in Part C isinconsistent with the assumptions and content ofsite specific allocations in Policies SP2, SP3, SP5,and Tables 1-3. Opportunity Area B MerchantQuarter identifies a Development Opportunity formixed use (max 50% [residential]). In SP2/Table 1and SP3/Table 2 there are instances where theassumed residential component exceeds 50%(IP043, IP052, 1P136). Development Principlessuggest that there should generally be a limit of 3storey development, rising to 5 storeys in someinstances, but for allocations IP136 and IP132, theassumed capacity is derived from a developmentscenario which is 10 storeys.

The schedules provided within Part C which describe thedevelopment opportunities and development principles should beconsistent with the development descriptions and capacity evidenceset out in Tables 1, 2 and 3 in Part B. Alternatively it should be madeclear which content will take precedence.


OpportunityArea C - MintQuarter / CoxLaneregenerationarea andsurroundingarea

OBJECT As with Area B, this is a complex and diverse areain terms of the historic environment. Currentreferences to the historic environment arewelcomed, but there needs to be greater detail withregards to scheduled monuments and archaeology.The large scheduled monument that runs throughthis area is not shown on either diagram, with'development options' mapped over the top. This ismisleading and does not provide sufficient clarity fordevelopment proposals.

In order to make the plan sound, the two diagrams for Area C shouldshow the extent of the area's scheduled monument. Given theuncertainty regarding the full extent of archaeology within this part ofIpswich, we do not require the 'development options' shading to bemodified, but the text before the table of developmentopportunities/principles should clarify that the full extent ofdevelopment will be subject to archaeological evaluation. We alsoconsider that the bullet point relating to scheduled monuments andarchaeology in the development principles column should beamended and strengthened along the lines of "development toaddress and conserve scheduled monuments and archaeology (muchof the Mint Quarter site is a scheduled monument)".


OpportunityArea C - MintQuarter / CoxLaneregenerationarea andsurroundingarea

OBJECT Mint Quarter (P64) - the name should be droppedas it is associated with failure. In addition to theproposals, we consider this site could be used forthe 'big-box retail cluster' outlined above. There mayalso be potential for it to be used as a single busstation, although the site currently occupied byJewsons may offer this potential also.


OpportunityArea D -EducationQuarter andsurroundingarea

OBJECT Support but require changes. References to thehistoric environment are welcomed, includingarchaeology, although there are three conservationareas which overlap this opportunity area, not justthe Wet Dock (also Central and St Helen's). Wenote the reference to a minimum of six storeysalong the waterfront which could have implicationsfor the historic environment, including the Wet DockConservation Area.


OpportunityArea D -EducationQuarter andsurroundingarea

OBJECT The County Council proposes a minor amendmentto the approach proposed for the EducationQuarter, to slightly widen the range of ancillaryeducation projects which could come forward in thearea. It is proposed that the final sentence of thefirst paragraph be amended as follows: 'Within thedefined Education Quarter, development foreducation and ancillary uses such as studentaccommodation, heritage and cultural facilities oroffices will be permitted.'

Final sentence of the first paragraph to be amended as follows:'Within the defined Education Quarter, development for education andancillary uses such as student accommodation, heritage and culturalfacilities or offices will be permitted.'


OpportunityArea E -Westgate

SUPPORT Although this area does not contain any designatedheritage asset, it is situated between twoconservation areas (Central and Burlington Road)and a number of listed buildings, including theGrade II* Churches of St Matthew and St Mary atthe Elms and the Grade I Willis Building. Part of thesite also lies within the area of archaeologicalimportance. We welcome the additional referenceto heritage assets and archaeology as adevelopment principle.


OpportunityArea F -River andPrincesStreetCorridor

SUPPORT This area contains a listed building and is situatednear to other listed buildings (e.g. the WillisBuilding) and the Central Conservation Area. Theremay also be archaeology issues, with the area ofarchaeological importance covering part of theopportunity area. We welcome the additionalreference to the historic environment as adevelopment principle.



OBJECT River and Princes Street Corridor (P74) - we havepreviously resisted comprehensive retaildevelopment on part of this site. We continue to doso and are pleased that this has been dropped inthe new plan. We consider there to be potential onthe waterfront element for residential development.We fully support new office development in PrincesStreet.



OBJECT The Opportunity Area guidance in Part C isinconsistent with the assumptions and content ofsite specific allocations in Policies SP2, SP3, SP5,and Tables 1-3. In Opportunity Area F, RiverCorridor, the Development Opportunity identified isfor office -led, mixed use with leisure and carparking. Under SP3, Site IP047 which lies withinthis Opportunity Area is allocated for residential-ledmixed uses.It is not clear which content will take precedence.

The schedules provided within Part C which describe thedevelopment opportunities and development principles should beconsistent with the development descriptions and capacity evidenceset out in Tables 1, 2 and 3 in Part B. Alternatively it should be madeclear which content will take precedence.

5358 Legal and GeneralAssurance SocietyLimited (L&G) (MrAlfred Yeatman)[1454]


OBJECT The Jewson site (IP028b/UC029) should beallocated as a development site and the frontagealong this site highlighted as an area for improvedpublic realm/pedestrian links. Its allocation [to meetthe scale and type of retail and leisure developmentneeded in town centres] would help meet theshortfall in sites against the identified needs. Thesite was identified as a development site withinOpportunity Area G (now F) at Preferred Optionsstage. L&G understand that the owners indicatedthat it would not come forward for redevelopment.However, L&G acquired the site in 2009 and thesite will now become available.

The boundary of Opportunity Area F should be drawn as perOpportunity Area G within the 2007 IP-One AAP Preferred Options.The Opportunity Area F Analysis map should highlight the Jewsonssite frontage as detracting from the urban structure an area forimproved public realm/ pedestrian links.The Opportunity Area F Development Option map should allocate theJewson site as a Development Option.Insert the following Development Principle from the 2007 IP-One AreaAction Plan into the Opportunity Area F - River Corridor and PrincessStreet Development Opportunities and Principles Table: "To improvelegibility of routes through Cardinal Park and between the station andthe shopping centre".

5515 Corindale PropertiesLtd [1424]

SP1 TheProtection ofallocatedsites

OBJECT The company's land located off Toller Road isannotated on the proposals map as asite to be used exclusively for employmentpurposes. This is considered to be unduly restrictivein the context of a still uncertain economy andignores attempts to market the site for employmentuse over 10 years. The policy ought to reflect that atthe very least an element of other land uses e.g.limited retail and/or residential should beincorporated into the policy for the allocation of thespecific parcel of land (reference 208). Theallocation should be changed or mixed use todeliver regeneration.

Either change the wording of policy SP1 and SP5 to provide forflexibility or in the alternative change the allocation for this specific sitefrom exclusively employment and retain for the purpose to that of amixed use containing an element of retail/residential as well asemployment.

5435 Coes (Mr WilliamCoe) [1435]

SP10 RetailSiteAllocation

OBJECT This policy of focussing on the Westgate seems tocontradict everything within that master plan andsends another skewed message in terms of wheredevelopment in the town should take place. Webelieve that the council should stick with the towncentre master plan and focus on the north/southaccess development rather than divert anything to aWestgate development, which runs contrary to thispolicy as set out in the master plan. We would urgethe Council, despite the so called knowledge of theDTZ report, to work together with local stakeholdersand follow the consensus view.



OBJECT SP10 is not positively prepared or justified as theallocations included do not seek to meet therequirement for comparison retail identified in theevidence base.Insufficient sites are identified to meet therequirements for retail floorspace over the planperiod, particularly for comparison goods. Theevidence base identifies a requirement for additionalretail floorspace. A single site is proposed for newretail development in the town centre (Westgate),which is carried forward as an existing commitment.The NPPF requires local planning authorities toallocate a range of suitable sites to meet the scaleand type of retail development needed.

Policy SP 10 should be amended to identify further retail allocationswhich will address the identified comparison and convenience retailcapacity within Ipswich to 2026 and 2031. Sites allocated in theWaterfront for mixed use development comprising small scale retailas well as other commercial, residential, leisure and cultural usesshould be allocated to allow for a more flexible quantum for the retailcomponent, to allow for a viable mix of uses to be developed.



OBJECT The DTZ report provides insufficient evidence tojustify the reduction in new retail floorspace. The2010 retail capacity study should be updated now toinform policy. Policy is not positively prepared andcould sterilise Ipswich town centre for medium tolarge scale retail development for 11 years, havingserious implications on the vitality and viability of thecentre. The Jewson site must be considered fortown centre use including retail.

Policy SP10 needs to be reworded to include allocation of commercialretail and leisure use at Site UC029 (Jewsons, land west of GreyfriarsRoad) [SHLAA reference IP028b]. Policy SP10 supporting text needsto be updated accordingly.


SP11 TheWaterfront

SUPPORT ABP welcomes the recognition given at paragraph5.20 (in support of Policy SP11) to the need for newdevelopment to take account of the Port'soperational needs given its situation within andadjacent to the Waterfront.


SP11 TheWaterfront

OBJECT SP11 is not positively prepared or justified as theallocations included do not seek to meet therequirement for comparison retail identified in theevidence base.Insufficient sites are identified to meet therequirements for retail floorspace over the planperiod, particularly for comparison goods. Theevidence base identifies a requirement for additionalretail floorspace. A single site is proposed for newretail development in the town centre (Westgate),which is carried forward as an existing commitment.The NPPF requires local planning authorities toallocate a range of suitable sites to meet the scaleand type of retail development needed.

Policy SP11 should be amended to identify further retail allocationswhich will address the identified comparison and convenience retailcapacity within Ipswich to 2026 and 2031. Sites in those parts of theWaterfront that lie within the identified town centre boundary that areallocated for mixed use development comprising small scale retail aswell as other commercial, residential, leisure and cultural uses shouldbe allocated to allow for a more flexible quantum for the retailcomponent, to allow for a viable mix of uses to be developed. TheCentral Shopping Area boundary should be extended to include themain routes through the Merchants Quarter at Star Lane and CollegeStreet.

5211 The Theatres Trust(Planning Adviser)[278]

SP14 Arts,Culture andTourism

OBJECT Support but require changes. The Theatres Trustsupports this Policy as it reflects guidance at item70 of the NPPF which states that planning policyshould protect existing cultural facilities.

However, it is a concern that it only covers facilitiesin the main town centre area. This type of policy isnormally included as a core strategy or a generaldevelopment policy.


SP14 Arts,Culture andTourism

OBJECT Policy SP14 (P44) - the support that the Councilshows for a conference/exhibition space iswelcomed, but substantially more detail is requiredfor what exactly is planned here and how it could beachieved. There has been talk of a new 'attraction'and, again, this needs consideration.


SP15ImprovingPedestrianand CycleRoutes

SUPPORT We also support improved pedestrian routes andvistas from the town centre to/from the Waterfront.Equally, we do not think that the traffic on Star Laneshould be thought of as preventing this.


SP15ImprovingPedestrianand CycleRoutes

OBJECT Upper Brook Street (P46) and Museum Street - wewould like to see both streets pedestrianised andhigh-quality residential development returned toMuseum Street south. The latter appears to beomitted.


SP16TransportProposals inIP-One

SUPPORT ABP welcomes the approach taken in the wordingof Policy SP16 and paragraph 5.46.

ABP recognises the desire for a new crossing andwill assist the Council in seeking to develop afeasible solution which addresses all safety, securityand operational issues and avoids any adverseimpact on port operations.


SP17 TownCentre CarParking

OBJECT RCP Parking Ltd object to the delineated boundaryof the central parking core asshown on the proposals map and considered that itshould be changed and extendedto include a number of sites which are making avery effective contribution towardsparking provision for the people of Ipswich and willdo so and can do so for theforeseeable future. In particular, the exclusion ofsites:-Duke Street on Orwell QuayPrinces StreetHand ford Road EastRanelagh Road,St Peter's Warehouse site on Bridge StreetShould be included and the boundary adjustedaccordingly.

Alter the specific delineation of the central parking core on theproposals map to include the site currently operated by RCP Ltd. aslisted above.



OBJECT RCP parking Ltd considers that the whole approachto the control of parking in the central area and thefuture of provision of multi-storey car parks isentirely aspirational and not deliverable. Further, thispolicy ignores the very real contribution that sitessuch as those operated for a temporary period forshort-stay parking (e.g. Handford Road, PrincesStreet, St Peters Warehouse site for example)make to the people working, shopping andundertaking leisure pursuits in Ipswich.

Change the policy to reflect the contribution made by short-stay carparking on vacant land for a temporary period thereby providingvaluable use for a number of stakeholders and making a contributiontowards Ipswich's parking needs. The council should recognise andaccept that vacant sites in the central area are a permanent feature ofthe dynamics of the property development cycle and that it is a validand sound planning objective to make best use of vacant land. Theyshould adjust Policy SP17 accordingly.



OBJECT Car Parking (SP17) - Ipswich must be made moreappealing to the car-borne visitor, not less. Plans torebuild Crown Street car park are to be welcomed.The new car park must include good quality spacesand a much improved link across Crown Street.


SP2 LandAllocated forhousing

SUPPORT ABP supports the allocation of Site IP037 - IslandSite for housing as part of a mixed usedevelopment. Given the nascent proposals for thesite, the notional housing capacity set out in thepolicy can only be indicative at this stage, althoughit is below ABP's expectations. ABP welcomes therecognition in the Policy that the precise split shouldbe a matter for a future master plan and/or planningapplication having regard to viability (consistent withpara 2.11).



SUPPORT It does not appear that any sites are undeliverablefor transport reasons when considered individuallyand if an assumption is made that proper provisionis made for sustainable transport measures andhighway mitigation. This statement needs to beconsidered against those made on the CoreStrategy and cumulative transport impacts.



OBJECT This document is only deliverable with sufficientinfrastructure. Indicative Section 106 costs(education, libraries, waste) and highwayrequirements are set out in the full representation.Early years: larger sites (>200 dwellings) may needto make on site provision.Primary: in principle, primary school places can beprovided (predicated on development fundingplaces, where compliant with the CILRegulations).Secondary: the new secondary school planned atGarden Suburb (CS10) will also need to mitigatedemand arising from background and housinggrowth across Ipswich.Sites should be deliverable with suitable (SFRA)flood risk measures. Archaeology does not preventsites being allocated.




5339 The KesgraveCovenant Ltd (MrCrispin Rope) [1439]


OBJECT The Core Strategy Review fails to identify eithersufficient specific deliverable sites for years 1-10 orbroad locations for the full housing requirement, andtherefore fails the tests of Soundness in terms ofEffectiveness, being Positively Prepared, and beingconsistent with the NPPF.

In accordance with our representations to the Core Strategy Review,there is a need to allocate additional strategic sites for the last part ofthe Plan period (2026-2031) or identify deliverable broad locations. Inthat context, land at North-East Ipswich should be identified on theKey Diagram and Site Allocations Proposals Map as a growth locationor strategic site for post 2026 development.





5190 ALDI stores Ltd (PeterGriffiths) [1060]

SP3 Landwith planningpermission orawaiting aSection 106

SUPPORT We continue our support for the allocation of aDistrict Centre at Sproughton Road.

We have concern in respect of the prescriptivenature of Uses being identified for site IP090,including that uses on the site should be in line withsite's historic planning permissions.

We request the Council acknowledges the NPPF(p.173) which states when pursing sustainabledevelopment careful attention is made to ensureviability and deliverability of schemes.

It's not suggested that residential is not possible,but rather the scale of residential must becommercially realistic and not impede upon deliveryof the commercial element of the Centre.

It is respectfully submitted that the creation of a District Centre is akey aim of the policy and has been identified as a much neededfacility to serve north east Ipswich, including significant housinggrowth in the area. In order for the new District Centre to competewith other Centres in Ipswich the scheme would be more suited as acommercially led scheme rather than a residential led scheme. Thiswould ensure viability and deliverability of the scheme and act in linewith the para.173 of the NPPF.

For the avoidance of doubt, it is not suggested that residential is notpossible, but rather the scale of residential must be commerciallyrealistic and not impede upon delivery of the commercial element ofthe District Centre.


SP3 Landwith planningpermission orawaiting aSection 106



5273 National Federation ofGypsy Liaison Groups(Mr Roger Yarwood)[1213]

SP4 Landprotected forGypsy andTravellersites

OBJECT SP4 is different to CS11 in the Core Strategy butthey cover the same activity. There should be asingle policy covering gypsies and travellers. PolicySP4 is not compliant with paragraph 10 of PlanningPolicy for Traveller sites under which criteria forconsidering applications should be established.Criteria a), b) and c) of SP4 should be deleted andapplications determined against criteria in the CoreStrategy.

Delete criteria a), b) and c) of SP4 and have a single policy for dealingwith applications for traveller sites.


SP5 Landallocated foremploymentuse

SUPPORT ABP supports the allocation of Site IP037 - IslandSite for employment as part of a mixed usedevelopment. Given the nascent proposals for thesite, the notional area/split set out in the policy canonly be indicative at this stage. ABP welcomes therecognition in the Policy that the precise split shouldbe a matter for a future master plan.




5614 Ashfield Land Limited(Mr Paul Derry) [1122]


OBJECT Ashfield Land supports the identification of the site'Land North of Whitton Lane' Site ref IP140 (UC257)for employment development. The site isstrategically located within the Ipswich Policy Areabeside the A14 and adjoins the existing Anglia Parkemployment area. Table 3 within draft policy SP5notes the site is 'suitable primarily for B1 with someB2 and B8'. Whilst the introduction of reference toclasses B2 and B8 is welcomed, the emphasis onclass B1 remains adversely restrictive.

5516 Corindale PropertiesLtd [1424]


OBJECT The company's land located off Toller Road isannotated on the proposals map as asite to be used exclusively for employmentpurposes. This is considered to be unduly restrictivein the context of a still uncertain economy andignores attempts to market the site for employmentuse over 10 years. The policy ought to reflect that atthe very least an element of other land uses e.g.limited retail and/or residential should beincorporated into the policy for the allocation of thespecific parcel of land (reference 208). Theallocation should be changed or mixed use todeliver regeneration.

Either change the wording of policy SP1 and SP5 to provide forflexibility or in the alternative change the allocation for this specific sitefrom exclusively employment and retain for the purpose to that of amixed use containing an element of retail/residential as well asemployment.






SP6 Landallocated andprotected asopen space

OBJECT ABP supports the overall site allocation (IP037) butrequests amendment to the wording of the policy toallow for a lesser amount of open space in theproportional split of acceptable uses where a masterplan or the preparation of more detailed proposalsshow this is appropriate and expedient.

Amendment to the wording of the policy to allow for a lesser amountof open space in the proportional split of acceptable uses where amaster plan or the preparation of more detailed proposals show this isappropriate and expedient.


SP7 Landallocated forleisure usesor communityfacilities



SP7 Landallocated forleisure usesor communityfacilities

OBJECT Policy SP7 does not allocate sufficient sites to meetthe projected demand for commercial leisure space.The Jewson site (IP028b/UC029) must beconsidered for town centre use including leisure.The [NPPF] requirement to allocate sufficient sitesfor leisure development is reinforced by the 2013DTZ report, which recognises that the centre has arelative lack of leisure and food/drink units. PolicySP7 allocates only one site for leisure development(the former Odeon Cinema, c. 2,500 sq m). Thisdoes not meet demand for commercial leisure(A3"A5 only) up to 2016 (forecast at 2,660-4,000sqm (net)).

Table 5 of Policy SP7 should be changed to include the Jewsons site,west of Greyfriars Road [SHLAA reference IP028b] allocated for towncentre use development including leisure.

5740 Private Individual SP8 OrwellCountry ParkExtension

OBJECT Object to a visitors centre because it will requireparking and a new access; it will bring people anddogs close to the SPA and increase pressure on it;IBC has not adequately managed the inter-tidal areato date; the site is already at saturation point forpublic recreation; cars via Gainsborough Lane orBridge Wood would pose a danger to people andimpair the local ambience; the centre would notbenefit local people; a centre would attractvandalism; the infrastructure and habitatmanagement of the park have been neglected. Thepark needs resources to warden and manage itproperly.

Delete visitor centre allocation. Provide more resources to manageand warden the country park.

5619 Natural England (MrJohn Jackson) [1413]

SP8 OrwellCountry ParkExtension

OBJECT Further to our previous concerns about Pond Hall,we welcome the inclusion of new policy SP8. IBChas committed to carrying out a study into visitoruse and bird disturbance around Orwell CountryPark and Pond Hall, which will provide a baselineand be used to inform visitor managementmeasures at the park. Natural England advises thatwith these measures in place, as informed by thestudy, the policy is not likely to have a significanteffect in terms of the Habitats Regulations. Theplanned visitor centre feasibility study should includea separate project level Habitats RegulationsAssessment.

As part of policy SP8, the Council will investigate further the feasibilityof including a visitor centre facility within the site, including anypotential impacts on the SPA. This feasibility study should include aseparate project level Habitats Regulations Assessment to examineeffects on the SPA.


SP9Safeguardingland fortransportinfrastructure

SUPPORT ABP is content with the wording in Policy SP9 as itrelates to Site IP037 that the development layoutshould not prejudice future provision of a Wet DockCrossing, provided that this does not ignore that thecritical challenge to realising successfulredevelopment of the Island Site will be viability(which is recognised at paragraph 2.11 as one ofthe more detailed issues emerging from theevidence which this plan needs to address).

Proposed Submission Supporting Documents

REPID

RESPONDENT NAME DOCUMENT SUPPORT/OBJECT


5398 Applekirk Properties Ltd(Teresa Cook) [1452]

Local Plan IP-OnePolicies Map Nov2014 (Amended07/01/2015)

OBJECT Applekirk Properties Ltd objects tothe IP-One Area Inset to the LocalPlan Policies Map as theboundary indicated for the Riverand Princes Street CorridorOpportunity Area is not justified asit is not consistent with theboundary shown in the Part C ofthe Site Allocations Plan.

The IP-One Area Inset to the Local PlanPolicies Map should be amended sothat the boundary shown on the Map forthe River and Princes Street CorridorOpportunity Area is the same as thatshown on the plan in Part C of the SiteAllocations Plan.

Strategic Environmental Assessment and Sustainability Appraisal - Site Allocations and Policies (incorporating IP-One Area Action Plan) DPD

REPID

RESPONDENT NAME CHAPTER SUPPORT /OBJECT


5509 Northern Fringe ProtectionGroup (Mr Brian Samuel)[976]

4.3 Appraisal ofSite Allocations

OBJECT The viability of the allocation of theWestgate site for Retail has beenquestioned by Ipswich Central and thealternative options proposed by IpswichCentral for Retail sites need to beconsidered in the SA of the SiteAllocations accordingly.

Alternative options for retail sitesproposed by Ipswich Central needto be considered in the SA.

5739 Save Our Country Spaces(Mrs Barbara Robinson)[978]

4.3 Appraisal ofSite Allocations

OBJECT SOCS endorse the Northern FringeProtection Group's points. The viability ofthe allocation of the Westgate site forRetail has been questioned by IpswichCentral and the alternative optionsproposed by Ipswich Central for Retailsites need to be considered in the SA ofthe Site Allocations accordingly.

Alternative options for retail sitesproposed by Ipswich Central needto be considered in the SA.

5621 Natural England (Mr JohnJackson) [1413]

Chapter 4:APPRAISAL OFTHE SITEALLOCATIONSDPD

OBJECT Natural England is reasonably satisfiedthat the SA considers the impacts of theCore Strategy and Policies [sic] onrelevant aspects of the environmentwithin our remit, including biodiversityand geology, landscape, greeninfrastructure and soils. We particularlywelcome SA objectives to protect andenhance designated sites, includingSSSIs, SACs, SPAs and Ramsar sites,in addition to locally designated and non-designated areas of biodiversity.However, we would advise that the SAshould cross-reference with the findingsand recommendations of the AA whichidentifies potential recreationaldisturbance effects on European sites,and measures to mitigate these.

We would advise that the SAshould cross-reference with thefindings and recommendations ofthe AA which identifies potentialrecreational disturbance effects onEuropean sites, and measures tomitigate these.