Town Centre and Waterfront – Public Realm Strategy Supplementary PlanningDocument, Consultation Statement, April 2019

Town and Country Planning (Local Development) Regulations 2012Consultation Statement in accordance with Regulation 12(a).

1. The Town and Country Planning (Local Development) Regulations 2012 stipulatein regulation 12(a) that, before adopting a supplementary planning document, thelocal planning authority must prepare a statement setting out:

i) The persons the local planning authority consulted when preparing thesupplementary planning document;

ii) A summary of the main issues raised by those persons, and;

iii) How those issues have been addressed in the supplementary planning document.

2. In accordance with regulation 12(a), this statement outlines the persons andorganisations consulted in preparing the Town Centre and Waterfront Public RealmStrategy Supplementary Planning Document (SPD) and sets out the responsesreceived to the consultation and how the issues raised have been addressed in thefinal version of the document. There have been two stages in the preparation of thePublic Realm Strategy SPD which have involved full public consultation. These are:

The Call for Ideas – ideas were sought on both the scope of the SPD andwhat it should cover and aspects of the Core Strategy policy approach to thepublic realm; and

Full Public Consultation on the Draft Town Centre and Waterfront PublicRealm Strategy SPD document once it had been prepared.

Information on how the views of individuals and organisations were sought isincluded in notes below. A summary of main points raised in consultation responsesand the response of the Council to these points is presented in tabular form undereach consultation stage, with the most recent first.

Consultation on the draft Town Centre and Waterfront Public Realm Strategy SPD16th January and 27th February 2019.

The consultation was carried out in accordance with the Ipswich Borough CouncilStatement of Community Involvement Review March 2018. It included:

making the document available for inspection on the website and as a hardcopy at specified venues, together with supporting documents;

alerting everyone on the Council’s Local Plan mailing list to the consultation;

alerting people to the consultation through the Council’s social mediachannels;

publishing a notice of consultation advising where and when comments maybe made;

placing a public notice in the local press; and

publishing Strategic Environmental Assessment and Habitats RegulationsAssessment screening reports.

The Council’s Local Plan mailing list includes the specific consultation bodies andgeneral consultation bodies specified through regulation 2 of the Town and CountryPlanning (Local Planning) (England) Regulations 2012, which includes HistoricEngland. It also includes private individuals who have opted to be notified of LocalPlan matters (see also Appendix 1 to the Statement of Community InvolvementReview March 2018

https://www.ipswich.gov.uk/sites/default/files/statement_of_community_involvement_review.pdf).

The table below sets out the feedback from the full public consultation on the draftTown Centre and Waterfront Public Realm Strategy SPD carried out between 16thJanuary and 27th February 2019, and the Council’s response indicating whether andwhere the document has been amended.

Table 1 Consultation comments received on the draft Town Centre and WaterfrontPublic Realm Strategy SPD.

Respondent Comment IBC responsePrivateindividual 1

With regards to the £3million on hold may Isuggest that some of it be used to revamp theCorn Hill.

Not relevant to the draft SPD.The comment offers an opinionon recently completed publicrealm works in the Cornhill.

Privateindividual 2

List in order in my opinion:1 & 2) at same time if poss ie Arras Square-near to Historic heart and incorporating T I, plusPrincess St bridge-important for firstimpressions from town centre rail station.3)Lloyds Ave-very desirable aim.4)Majors corner-very long term.

Not relevant to the draft SPD.The comment offers an opinionon a shortlist of preferred sitesfor public realm investment,following a separateconsultation exercise by IBC.

Privateindividual 3

I feel that the best place to improve would beArras Square. The TIC is much used and givesa good impression to visitors. The outsideought to do the same.A play area outside St Lawrence might be goodbut outside the old SSoffice at Tower st wouldbe bigger and perhaps more open.What is really needed for visitors to Ipswich byprivate coach is a loo at Crown St lay-by orsomewhere very near.

The Arras Square commentrefers to a separate IBCconsultation on preferred sitesfor public realm investment.The suggestion of a play areaat St Lawrences is containedwithin the draft document atpage 43 (Key Location ProjectX). The space in front of theformer SCC office at Tower Stis private land and currentlyused for carparking.

Privateindividual 4

I think the area most in need of investment isArras Square

Not relevant to the draft SPD.The comment offers an opinionon a shortlist of preferred sitesfor public realm investment,following a separateconsultation exercise by IBC.

Respondent Comment IBC responsePrivateindividual 5

1. I welcome the plan overall and agree withstatements in the introduction about the wealthof public realm assets including the historictownscape and buildings. I endorse theambition to make Ipswich a more beautifulplace – the potential is there. Currently thevibrancy of the town centre is also more in itspotential than reality.

1.6 I welcome and endorse the key deliverablethemes, especially for greater connectivity andidentity, but in some areas the proposals don’tgo far enough. I have a concern that whileindividually laudable, the multitude of smallprojects may result in a patchwork of good andbad parts, and fail to achieve the larger visionfor coherence, identity and beauty.

1.9 The nine themes are clear but there are toomany. Consider focusing on ‘designing forpeople’ and ‘prioritising walking’ as these woulddeliver on all the other themes. There is aconflict between the objectives of ‘prioritisingwalking’ and ‘balancing vehicular movement’ infailing to address the out-dated, damaging,dangerous and ugly gyratory system thatdivides the town from the waterfront asidentified in the Allies and Morrison “Ideas forIpswich” document published in 2018.

It would be so disappointing to improvepedestrian access across the derelict St Peter’sPort area to be met by HGVs and other trafficcramped into the narrow College Street / KeyStreet. Pedestrianising College Street andmaking Star Lane 2-way is the single mosteffective measure to make Ipswich morebeautiful, enhance its identity and developnorth/south connectivity.

Some suggestions for strengthening identityand north-south connectivity:• Ensure visual coherence, de-cluttering, andcelebrate the heritage of the medieval town• Making College Street / Key Street pedestrianalso offers the opportunity to make a pedestrianroute from Fore Street, Salthouse Street andthrough to Wherry Lane, going from the heart ofthe town to the heart of the Waterfront. Thiswould enlarge and enhance the sense of publicrealm and public life, and encourage greateruse of the East side of the Waterfront.

i) The comment about SPDparagraph 1.6 refers to thestrategic aspects of thedocument. Appendix 1addresses this commentthrough the identification of‘Street Types’ which sharedesign characteristics whichcan be reinforced throughissues such as surfacingdesign, street lighting, streetfurniture.

ii) The comment aboutparagraph 1.9 raises some longterm issues about the highwaysdesign of the town centre whichare beyond the strict scope ofthe SPD, even if they ultimatelyhave a direct impact upon thefunctioning of the public realm.The redesign of the waterfrontgyratory would undoubtedlyimprove north-south pedestrianconnectivity as well asenhancing the east-westwaterfront corridor, but theproposal involves significantredesign of the vehiclecirculation network, on a scalenot currently beingcontemplated. The SPD could,however, have a significantimpact upon future highwaysstrategies that might addressthis issue.

iii) Pedestrian prioritisationsuggestions:

Zebra / toucan crossings. Thedesign and placement ofcrossings is an SCC (SuffolkCounty Council) issue, as theHighways Authority. Theconcerns expressed in thecomment will be referred toSCC.

Prohibition of HGVs betweencertain times. HGV access forloading and unloading isalready restricted withinpedestrianised areas between

Respondent Comment IBC responseSome suggestions for prioritising walking: •Within the SPD designated area make allpedestrian crossings Zebra Crossings withToucans retained for vulnerable people andthose with sight impairments. In myexperience, Zebras have a traffic calmingimpact with drivers taking note of what ishappening around them rather than racing tobeat the Toucan lights. Drivers can vary theirspeed as they approach Zebras and thereforeoften don’t need to stop, and certainly don’tneed to stop when pedestrians have alreadycrossed in a break in traffic. Toucans shouldalso have a maximum wait of 10 seconds inbuild up areas to change in favour ofpedestrians – longer waits encourage them totake risks in crossing.• Prohibit lorries and HGVs driving through thetown at certain times, eg rush hours, limit themto 10.00am and 3.00pm.• The vibrancy of the town centre is inhibited bythe cost of car parking which is charged by thehour. In contrast, drivers can park in out-of-town retail parks for free for as long as theylike. The playing field could be partiallybalanced by introducing free parking in acouple of carparks during the daytime. I haveyet to see a full carpark in Ipswich and thiscontributes to a dismal sense of decline.• Ban ‘A boards’ on pavements – theycontribute to visual clutter and present hazardsto pedestrians on narrow pavementsSome suggestions for designing for people:• Ensure coherence and quality of designacross the SPD area• Provide consistent hanging signs forindependent businesses along St Peter’sStreet, Fore Street and other historic streets –this has been done is certain streets in London,eg Lamb’s Conduit Street and effectivelyenhances the identity, beauty and consistencyof the area• Consistent road and pavement surfaces –using the same materials across the whole areaadds to coherence; consistent / coherentdesign of seating, lighting and sea-gull-proofwaste bins• Avoid ‘trails’ embedded into pavements etc asthey soon become dated, plaques on buildingscelebrate the town’s heritage more effectivelyand can be included in paper-based ‘walkingtrails’• Consider the quality of public art and see it ascontributing to the character of the town. It may

10:30 and 4:30. This will beextended if the pedestrianisedareas of the town centre areextended. Restricting HGVaccess on the public roadswithin the town centre is anSCC highways issue beyondthe scope of the SPD. Theconcerns expressed in thecomment will be referred toSCC.

Car parking costs. Only aproportion of town centrecarparks are owned by IBC.Council owned parking isgenerally cheaper than privateparking, but the Council has togenerate an income from itsassets. In addition, thedistortion of demand that wouldbe created through free parkingwould make vehicle movementswithin the town centre moredifficult to manage. The Councilis, however, aware of the needto meet the demand for parking,and is currently conducting acarparking strategy which willgovern the future planning ofnew parking provision.

A boards on pavements.Planning consent is required forA-boards paced on thepavement. It is only permitted toplace them, without consent, onprivate business forecourts.IBC, as the planning authority,would refuse an application forboards which blocked thehighway or causedunnecessary visual clutter.

Hanging signs. The Councilsshopfront design SPD providesguidance on the design of thiskind of advertising. It does notattempt to enforce identical signdimensions, as there is noconsensus for this approach inany of the towns commercialareas, but sets standards(especially in our more historic

Respondent Comment IBC responsebe that a small number of pieces that arequirky, human scale and light-heated – alongthe lines of the Giles statue would do more forthe town’s identity than any more meaninglessor obscure pieces like the concrete pillars in theCornhill

i. St Peter’s Dock – greatly welcome andentirely endorse plan to realign the pedestriancrossing east / west over Stoke Bridge toconnect Grafton Way and St Peter’s Dock andthe provision of a pedestrian route connectingto Wolsey’s Gate, which would be much moreattractive if College Street was no longer a dualcarriage-way race track.North-south connections are entirely focusedon the west end of the Waterfront, currently theleast attractive area and mainly still derelict. Apedestrian route along Fore Street, SalthouseStreet and Wherry Lane would create newconnections further West, nearer the Universityand embrace some of the gems of Ipswich.11. Bridge Street Gateway – the Star LaneGyratory is the single biggest problem andbarrier to north-south connectivity, is damagingto the historic buildings along College Street,inhibits development of the derelict sites at theentrance to the Waterfront, as well as beingugly and dangerous. Zebra crossings would bebetter than Toucan crossings.iii. St Peter’s Port area – welcome the ambitionto address the derelict site and enhance thesetting for Wolsey Gate. A pop-up gardenmight be one solution.Removing the temporary wire barriers would bean immediate improvement. There is no evidentlogic to fencing off the area of wasteland. Thistype of temporary fencing should be temporaryand only allowed for up to 6 months.The pedestrian route along the southern part ofFoundation Street already exists but leadsnowhere, only to a dual carriageway – routesneed to connect places that people want towalk between. If College Street was lessdangerous, St Mary at the Quay could use itsfront door rather than face the car park.viii. Princess Street Bridge gateway – thestation needs to be seen as the gateway toIpswich. Currently, visitors have the choice ofwalking along ‘dustbin alley’ (Burrell Road) orvia ‘shed row’ to the town or waterfront. Thefront of the station is already fit for purpose andattractive, there is a danger that public art willdiminish both its design and its utility.

streets) regarding the positionof signs on frontages, theoverall size and type of signs,and the preservation of historicfascias.

Consistency andappropriateness in the designof paving, street furniture,lighting and street planting isencouraged in several sectionsof the SPD including Chapter 3:Design Guidance and Appendix1: Design Approach, StreetTypes.

Careful design of ‘trails’. It is, asthe commentator notes,important to avoid redundancyin the design of trails. Additionaltext added to SupportingProject 40 ‘Discover IpswichTrails’, referring to the need toconsult during traildevelopment, to ensure thatpopular and durable links areestablished.

Public art. The SPDencourages site specific andrelevant artwork that adds tothe attractiveness and interestof an area – the Giles statuebeing a perfect example. Moredetailed guidance on thesubject of public art is beyondthe scope of this SPD.

(i) St Peter’s Dock. Regardingthe point about enhancingwaterfront connections on theeast side of the town centre,several projects address theseareas, including Key Locationprojects (vi) Upper Orwell Stand (vii) Regent Gateway /Majors Corner and Supportingprojects nos 20 Fore St Poolarea, 21 St Michaels and 32Christ Church Cox Lane.

(11) Bridge St Gateway. It is notcurrently practicable to redirecttraffic from the gyratory,

Respondent Comment IBC responseWelcoming signage to parts of the town otherthan the football ground is more important.Adjusting the traffic lights to prioritisepedestrians and taxis would be animprovement. 14. St Peters Street – a goodpace to ban ‘A boards’ on the pavement andprovide consistently designed hanging signs.Feature lighting could be helpful and should bemagical and twinkling in style 24. RiverPath – the potential to widen the path andprovide lighting would really enhance this assetwhich is currently under-used as it does not feelsafe. 25, 26. Waterfront north and eastside – the lighting needs to be maintainedrather than replaced by something morecontemporary, if they have to be replaced thecurrent twinkly, magical character should bemaintained. Extending the lighting and seatingalong the east side would improve visualcoherency encourage people to walk furtheralong the Waterfront, but there is still limitedreason to do so – the pedestrian crossing overthe dock would have helped, as would the re-opening of the Brewery Tap – as it stands thewalk is a dead end. A walking connection alongFore Street, Salthouse Street and Wherry Lanewould encourage more use of the East side ofthe Waterfront and embrace some of thehistoric gems of the town.32. Tacket Street – ban A frames on thefootpath and provide hinging signs – this is oneof the worst streets for footpath clutter. 33.Burrell Road link – a really dreadful, ugly butmajor route from the station to the waterfront.The dustbins on the pavement outside thehouses of multiple occupancy are the worstaspect and narrows the pavement to requirestepping onto the road at times. The loss of theisland crossing from Burrell Road northside tothe station leaves pedestrians without a safe,sensible crossing – vehicles have beenprioritised over walkers.

because of the consequentimpacts upon vehicle circulationthroughout the town centre. Itsfuture remains under review,however. Crossing types areunder the control of SCC, theHighways Authority. Theseconcerns will be passed on fortheir consideration.

(iii) St Peters Port Area. Pop upgarden idea is noted; commentincluded in text. Regarding thefencing, the land is privatelyowned and the fencing meets alegitimate security need. Themanagement of the site is,however, subject to monitoringby the Council.

(viii) Princess St bridgegateway. The public artproposal is adaptable to anumber of locations within thevicinity of the bridge, includingon the bridge itself. It will notnecessarily be located withinthe station concourse areawhere space is indeed quiterestricted.

(14) St Peters St. A boards onpavements. Planning consent isrequired for A-boards paced onthe pavement. It is onlypermitted to place them, withoutconsent, on private businessforecourts. IBC, as the planningauthority, would refuse anapplication for boards whichblocked the highway or causedunnecessary visual clutter. Thelighting spec will be givencareful consideration in such aprominent area, but the SPDavoids being overly specific indesign specification.

(24) River path. Commentnoted.

(25, 26) Waterfront North andEast side. Comments noted.

Respondent Comment IBC response(32) Tacket St. A boards onpavements. Planning consent isrequired for A-boards paced onthe pavement. It is onlypermitted to place them, withoutconsent, on private businessforecourts. IBC, as the planningauthority, would refuse anapplication for boards whichblocked the highway or causedunnecessary visual clutter.

(33) Burrell Road link.Comment noted about the binstorage. Many HMOconversions, for instance withinconventional terraced housingare below the threshold (ofindividuals involved) requiringplanning permission. Decisionsregarding pedestrian islandsare made by the HighwaysAuthority, Suffolk CountyCouncil, and the comment willbe passed on for their attention.

TheatresTrust

4.2.vii In principle the Trust is supportive of theCouncil’s aspiration to transform the southernend of the theatre car park to create a newpublic square and entrance space for theRegent Theatre. This would improve theenvironment around the theatre and enhancethe experience of visitors to the theatre. Wewould just note that any intervention of thisnature which reduces the car park area ensuresthe theatre’s needs for get-in/get-out andgeneral servicing requirements are protected.We are also supportive of the re-use orredevelopment of the former Odeon, bringing aprominent site within the town back to activeuse. We would however caution that shouldresidential use be promoted at this site thedesign guidance should make clear it must beappropriately soundproofed so as to avoidconflict with the neighbouring theatre. Thisprinciple has been included within paragraph182 of the NPPF (2018).36. In common with our formal response torecent planning applications concerning thepublic square outside the New Wolsey Theatre,we are supportive of efforts including a newcrossing across Civic Drive which wouldenhance the environment and public realm andimprove pedestrian connectivity andpermeability to and through the area.

Key Location Project (vii) –Regents Gateway / MajorsCorner. Comments noted. Anyproject affecting the theatreenvironment would be carriedout in close consultation withthe theatre management.Residential development of theOdeon site would be subject tonormal planning consultationrequirements, and this wouldinclude neighbouring uses suchas the theatre.

(36) St Matthews Greenspace.Comments noted.

Respondent Comment IBC responseSportsEngland

Sport England is supportive of this documentbecause it seeks to enhance the public realm inIpswich Town Centre, making it more attractivefor people to engage in informal activity such aswalking and cycling.Sport England, in conjunction with PublicHealth England, has produced ‘Active Design’(October 2015), a guide to planning newdevelopments that create the right environmentto help people get more active, in the interestsof health and wellbeing. The guidance sets outten key principles for ensuring newdevelopments/master plans incorporateopportunities for people to take part in sportand physical activity. The Active Designprinciples are aimed at contributing towards theGovernment’s desire for the planning system topromote healthy communities through goodurban design. Sport England would commendthe use of the guidance in the master planningprocess for new residential developments. Thedocument can be downloaded via the followinglink: http://www.sportengland.org/activedesign

Comments noted.

SuffolkConstabularySouthernArea PolicingCommand

Comments in relation to the general strategyoutlined in sections 1-3:SeatingWhilst seating can be beneficial to the town, itcan also encourage congregations of peoplewhose behaviour then impacts negatively ontoneighbouring properties, residents andbusinesses. In order to mitigate this risk;· seating should only be located in areas wherethere is high passing footfall and good naturalsurveillance. This includes in places such aschurchyards.· Seating should not be located against a wallor building to ensure maximum surveillance andprevent the seating being used as a climbingaid to gain access to private areas.· Seating must be designed to prevent peoplefrom sleeping or cycling/skateboarding on it (forexample with arm rests along a bench or seatsthat are a curved shape).· Seating should be designed such thatpackages cannot be concealed on or underthem.Public ParksIpswich has several large and establishedparks which are well used by members of thecommunity and an asset to the town. However,they have increasingly become hotspots fordrug related activity. There is a fine balance tobe struck between providing a relaxing natural

Seating. Comments noted. Itmay be necessary to seekcompromise in some instances,but the points raised are alsogood general design practice.Comments incorporated intoSection 3, ‘Design for Security’

Public Parks. The SPD doesnot include any of the largerpublic parks, although it doesinclude smaller areas such aschurchyards, where theserecommendations could apply.Comments incorporated intoSection 3, ‘Design for Security’

Respondent Comment IBC responseenvironment and deterring this sort of activitybut where possible;· natural surveillance should be encouraged bykeeping vegetation cut back.· Consideration should be given to the provisionof toilet facilities in the park. Maximising naturalsurveillance around the toilet blocks, reducingthe opening hours and carrying out regularchecks on the toilet may assist in deterringcriminal activity. Redevelopment of the blocksto create individual cubicles opening directlyonto the street should also be considered.Cycle storageCycle crime is high in the town centre and thefear of having a bike stolen will deter somepeople from bringing their bikes into town. Inmany cases, cycles locks are cut or forced inorder to steal the bikes. In order to mitigate therisk of thefts:· Consider a scheme whereby Sold SecureGold standard D locks could be loaned for areturnable deposit from public buildings withcycle storage nearby (i.e. libraries, sportsfacilities etc). Ideally these locks would be usedin addition to the owners lock.· Ensure cycle facilities are covered bymonitored CCTV.LightingGood lighting can enhance both natural andformal surveillance. However, care must betaken to avoid illuminating areas that are notsubject to regular surveillance as this mayencourage congregations of people behaving ina negative manner.CCTVCCTV coverage is often negatively impactedupon by tree coverage, especially when thetrees are in leaf. Planting and pruningstrategies must take this into account.Embedding technologyProviding public charging points and free Wi-Fican also encourage negative congregations ofpeople. Any such facility should be within anarea subject to close surveillance and have thefacility to be disabled quickly as required.Bus sheltersBus shelters should be located in places ofgood natural surveillance and not against wallsto encourage natural surveillance.Waste binsWaste bins should be constructed oftransparent material to reduce the risk ofsuspect packages being left in them and to

Cycle storage. Commentsnoted.

Lighting. Comments noted.Lighting schemes will beplanned with security as well asaesthetic considerations inmind. Do not agree withcomment that unsupervisedareas should also be poorly lit –this creates a security hazard.

CCTV. A balance will need tobe struck between the need tocreate pleasant environmentsand to provide adequatesecurity surveillance.Comments incorporated intoSection 3, ‘Design for Security’

Embedding technology.Comments noted.

Bus shelters. Guidance on busshelter location is provided inDesign Guidance section, page72. It recommends clear spacebehind bus stops.

Waste bins. Comments noted,but do not agree that thecontents should be visible – notaesthetically desirable and

Respondent Comment IBC responsemaximise the opportunity for detection if this isthe case.BollardsCare should be taken to ensure that bollards orother street furniture to deter traffic should bedesigned to avoid being possible to sit upon,especially in areas not subject to goodsurveillance.Key Location ProjectsThe generic points made above should beapplied to each of the key location projects andthe DOCO consulted when more detailed plansare known. However, please see below somecomments in response to the details providedthus far:i. St Peter's Dock· Planters/bollards or similar street furnitureshould be installed to provide protection tousers of quayside café facilities from vehiclessharing the space.· Ensure that narrow passageways betweenbuildings are subject to good quality monitoredCCTV.· Investigate methods of collecting waste fromthe water to avoid the 'broken window' effectwhereby more rubbish and crime is generated.· Ensure that any new boardwalks areinaccessible from underneath to deter roughsleeping or drug related activity.ii. Bridge Street gateway· Ensure that any tree planting in front of thechurch does not obscure natural or formalsurveillance.iii. St Peter's Port area· Ensure that planting does not obscure naturalsurveillance from the road.· Ensure that any seating is subject to goodnatural surveillance.· If a play space is proposed, build in the optionto make it secure in the evenings if requiredand avoid installing any equipment that couldbe used to conceal drugs or weapons.· If the rear of the church yard is to be openedup, ensure that this will not allow access intosecluded areas within the church yard that hadpreviously been secure.iv. Westgate/Tavern/Carr streets· Install barriers to deter vehicular access out ofagreed times (ie at Majors Corner and alsofrom Northgate St).· Ensure that street furniture (ie benches,planters etc) provide protection for pedestrianswhen vehicular access is required.v. Upper Brook St/Northgate

some semi transparentmaterials, eg perforated steel,are less resistant to vandalism.

Bollards. Comments noted. Theexisting recommendation onpage 68 (Design Guidancesection) is for as few bollardsas possible, using moreinformal elements to createseparation.

(i) St Peters Dock. Disagreethat this comment should beadded as suggested. Use ofstreet furniture to provideinformal separation can beconsidered, although it is alsopossible to create separationthrough, eg shallow kerbs, ason the existing waterfront.

CCTV. Disagree that thisshould be identified as a distinctpoint; the design proposals aregeneral in character and aCCTV coverage assessmentwill be part of a detailed designapproach.

Collection of rubbish fromwater. Comment noted.Comment added to KeyLocation Project (i)

Boardwalk security. Specialisedsecurity point – too detailed forSPD.

(ii) Bridge Street Gateway.Points noted. Treemanagement in churchyards isa specialist area associatedwith the environmental andheritage value of the treespecimens. Security issues willbe assessed as part of theseconsiderations.

(iii) St Peters Port. Points aboutensuring adequate surveillanceare noted, but the individual

Respondent Comment IBC response· Ensure that there is clear physicaldemarcation between the pedestrian areas andthose intended for vehicles and cycles. Forexample, if the loading and disabled bays are tobe raised to footway level, ensure that there isa barrier to prevent the pavements being drivenor parked upon.vi. Upper Orwell Street streetscape· Redevelopment of the public realm areaadjacent to St Michael's church is welcomed.Steps should be taken to prevent access to theneighbouring flats unless there is right ofaccess. Access into the private car park behindthis land must also be restricted. Considerationto be given to selling this land for privatedevelopment.vii. Regent Gateway/Major's Corner· As per the generic points — paying particularattention to the importance of not obscuringCCTV with new or existing trees.· Consider totally redeveloping the toilet blockto consist of individual cubicles accessingdirectly onto the street to deter drug use in thecubicles.viii. Princes Street Bridge gateway· Ensure that there is no access under thebridge from the station side to deter roughsleepers/drug related activity.ix. Arras Square/St Stephens· This is currently a priority area for police dueto the volume of incidents relating to ASB andissues relating to the street community.· The proposed development is broadlywelcomed, in particular the thinning of the treesand repairs to the paved areas. Wherepossible, surfaces should be level or slopedand steps avoided. Any benches in this areamust be close to areas of high footfall andformal surveillance.· It is also suggested that the audio function isenabled on the existing CCTV to allow IBC staffto converse with anyone acting inappropriatelyin this area.· Consideration may also be given to installingconvex mirrors at the rear of Wilkinsons inorder to increase natural surveillance over thearea.· The owners of the service yard should beencouraged to remove/reduce the height of thedividing wall to increase natural and formalsurveillance along St Stephen's Lane. A barriersuch as welded mesh could still be used tocreate a boundary if required.

points raised are too detailed tobe inserted into the SPD.

iv) Westgate. Comments noted.

v) Upper Brook St / NorthgateSt. Disagree withrecommendation for insertion ofadditional barriers within analready restricted pavementspace, unless essential. Also,disagree with proposal todemarcate cycle areas;segregating uses leads tohigher speed cycling.

(vi) Upper Orwell streetscape.Comments noted. New designswill seek to eliminate redundantspace.

(vii) Regent Gateway/Major'sCorner. Comments noted

(viii) Princes St bridgeGateway. Comments noted.

(ix) Arras Square/St Stephens.Comments noted. CCTV audiofunction is a valid point, but toosecurity-specific for the SPD.Disagree with the installation ofconvex mirrors; a traffic-management measure notappropriate in a pedestrianarea. Disagree with theproposed lowering of the wallon the south side of thechurchyard, which currentlyhelps screen the unsightlyservice yard from the mainpedestrian area.Removal of recessed doorwayscould be considered in unlistedbuildings, but this is a specificsecurity measure notappropriate to a public realmSPD.Metal railings to churchyard.Security fencing of any kindwould not be appropriate in alisted building setting, but amore designed approach toseparation between paving and

Respondent Comment IBC response· The recessed doors along St Stephen'schurch lane should be brought forward to detercongregation and rough sleeping.· Monitored CCTV must be installed along StStephens Church Lane.· Consideration should be given to erectingmetal railings along the outer edge of theretaining wall of the graveyard area. Gatescould be opened to allow families and membersof the public access during the summer butsecured at night or times when there mayotherwise be anti-social congregation in thisarea.· Relocate the cycle parking area so that it is tothe left of the rear entrance of BHS where it willbe subject to better natural surveillance.x. St Lawrence Church area· Include CCTV coverage of this area.· Consider enclosing this area so that it cansafely be used by customers of the cafesadjoining the area, but is not a cutthrough/escape route into a secluded area.Gates that were closed but not locked wouldassist this and deter (drug related) ASB beingdisplaced from nearby locations wherepartnership work is currently underway toprevent it.xi. Tower Street and Tower Ramparts East.· Ensure that any consolidated area forcommercial bins in Tower St is enclosed andaccessible only to the owners and wastecollectors to avoid rough sleeping/drug activity.· Seating should only be provided in areassubject to high footfall and surveillance.· Consider if public access around Oak Laneand Hatton Court are necessary 24/7 as this isan area that attracts a high volume of drugrelated activity and other criminal behaviour.· Consider the use of cycle lockers in this areainstead of simple racks.xii. Lloyds Avenue· Shared surface streets are not encouraged inthis area. This would mean no protection forpedestrians using the area. As this is a longstretch of road which then leads into the mainCorn Exchange area, the risk from hostilevehicles could not be ruled out.It is understood that funding is limited andtherefore the level of work that can be achievedis limited. Therefore specific comments havenot been made on the 'Other SupportingProjects'

churchyard might beconsidered. Comment added toKey Location project (ix)Cycle parking point noted.

(x) St Lawrence Church area.Creating partial enclosure /more controlled access to thearea could be considered.Comment added to KeyLocation Project (x)

(xi) Tower Street and TowerRamparts East.Bin and seating commentsnoted

Restricted access to Oak lane –Comment noted

Cycle lockers – Comment noted

(xii) Lloyds Avenue. Disagreewith comment about avoidingshared surfacing in this area.The street environment can bemanaged with informal barrierssuch as tree planting, seatingetc, to restrict vehicle access.

IpswichCentral

1.3 - the rationale for the strategy is set out as(a) helping to boost confidence and image, and

1.3. These are interdependentobjectives; the SPD addresses

Respondent Comment IBC response(b) acting as a catalyst for further developmentand investment. Our view is the driving forcemust be (b) rather than simply (a).1.6 – we recommend that a key theme for anyinvestment must be that it is consistent with theagreed Vision for Ipswich, which is to develop‘East Anglia’s Waterfront Town Centre’.Partners to the Vision (including ourselves andIpswich Borough Council) agree that the priorityis to ‘turn the town around’ such that its historiceast-west trajectory is replaced by a north-south axis, better linking the retail andcommercial core with the Waterfront.Investment in the public realm needs to beconsistent with this priority. Additionally, theunique selling points for any place shouldfurther inform both its Vision and any resultantinvestment strategy – in our view, this shouldprioritise Ipswich’s dominant role as a ‘culturalcapital’ alongside the ambition to be EastAnglia’s Waterfront Town Centre, and culturalassets should be preserved and enhanced aspoints of distinction.1.8 – here, the north-south axis is mentioned,but alongside the ambition to “improve [the]Carr-Tavern-Westgate route”. Given the crisisin the retail sector, it is unrealistic to expectlarge swathes of this former ‘golden mile’ toever be returned to gainful commercial activity,and alternative uses (yet to be delivered) willneed to be agreed. At this stage, we wouldstrongly resist public investment in anythingother than the current retail core (Cornhill andextensions; Buttermarket and surround) whichare the areas around which renewed“development and investment” will most likelysupport such spend.3.5 – we have some concerns here that designguidance will reflect current uses of the space.Town centres are changing fast and future usesmust be anticipated in line with the IpswichVision. Often, more ambitious treatments arebetter suited to stimulating “development andinvestment” rather than more anonymousoutcomes.Street furniture – we agree with the proposal toremove all unnecessary street “clutter” andwould suggest an audit is undertaken of thewhole town centre (including work undertaken)prior to any major public realm commencing asthis would, on its own, benefit many areas.3.8/3.10 – we recommend far more ambitiousseating designs than those illustrated.

the need to improve the town’simage and also to focusinvestment in areas most likelyto produce economic benefits.1.6. Although not a primarysource for the design strategy,the Ipswich Vision of improvednorth-south connectivity isexpressed through the objectiveof improving connectivitybetween key places, and thesignificant number of KeyLocation Projects andSupporting Projects whichcoincide with the identified town/ waterfront routes – see mapon page 79.Cultural assets are givenprominence in the Strategythrough the Objectives (1.9) ofstrengthening identity,celebrating public life,prioritising walking, enhancinglegibility. Many projects aredesigned specifically toenhance the public realmsettings of historic buildings andimportant public uses such asthe museum on the High St.1.8. The focus of public realminvestment will remain subjectto review. The number andcoverage of projects ensuresthat choices are available tomeet the evolving requirementsof the town centre, for instancein response to the contractionof the traditional retail core.3.5. The recommendation toanalyse existing uses is astarting point for design, not anend point. It follows goodpractice to establish existingpatterns of use, as it drawsattention to weaknesses as wellas strengths. Once identified, adesign decision could be tochange a pattern of use ratherthan retain or enhance it.Proposed street audit –comment added to 3.7 StreetFurniture Strategy

Respondent Comment IBC response3.11 – wherever possible, and beneficial, wewould like to see surfacing treatments thatbecome an attraction in themselves throughinnovative, rather than conventional, designsolutions.3.12 – wherever possible a ‘tree-linedboulevard’ approach should be adopted (e.g.Museum Street, Lloyds Avenue etc.).3.13 – in a similar way to the surfacingtreatment, we would advocate creative use oflighting, not just to illuminate buildings andspaces, but to enliven them such that theybecome an attraction in their own right.3.14 – we would like to see damagedwayfinding signage repaired and maintained. Itshould also have improved digital connectivity.4.2 – in outlining our priority projects, we returnto our main point made in response to 1.3 and1.8, which, combined, lead us to stronglyrecommend that proposed schemes areprioritised according to (a) their contribution toimproving north-south linkages, and (b) theiracting as a catalyst for further development andinvestment. We are also mindful that work to StPeter’s Dock (i) is underway, funded by aCoastal Communities grant.

Further comments received following on fromthe (4 projects) Public Spaces consultation.These set out Ipswich Central priority ofprojects provided - in no particular order are:viii – Princes Street Bridgeix – Arras Squarexii – Lloyds Avenue

3.8/3.10. Seating choices,along with other street furnitureselection, will be undertakenaccording to the conditions ofthe space and the requirementsof the design. Bespoke seatingdesign of the type installed inthe Cornhill recently is notexcluded from the SPD.

3.11. Dependent upon location,highly distinctive paving designwill always be a consideration –the green granite setts in theCornhill, for instance. Practicalconsiderations will always berelevant, however, such as thefunds available formaintenance, the availability ofreplacement paving in thefuture, the involvement of thehighways authority, and theneed to bear loads in traffickedareas.

3.12. Ipswich town centre hasnarrow medieval streets whichdo not lend themselves readilyto street tree planting. There ismore potential for Individual orgroup trees in squares orchurchyards.

3.13. There are a number ofexamples of recommendationsinvolving the creative use oflight sources. See, for example,Key location projects (iii), (vii),(viii), (x)

JTSPartnership

Cardinal Lofts (Mill) Ltd owns the freeholdinterest in a number of sites located towardsthe western end of the Waterfront / Wet Dockarea. These representations, made in respectof the Town Centre and Waterfront —Public Realm Strategy SPD should be read inconjunction with the related representationsthat are to be made, by the Company, inrespect of Ipswich Local Plan Review.Introduction. The Company welcomes, andsupports, both the objectives (para 1.6) andthemes (para 1.9), as set out in this section.The Company does, however, suggest that anadditional theme should be included within the

Para 1.9 ‘Achieving theObjectives’. The SPD sets outin para 1.3 the benefits of urbanrenewal; ‘bringing higher footfalland more commercial activity.Tangible, physicalimprovements will help boostconfidence and image, and helpcatalyse further developmentand investment, underpinninglong term resilience andcompetitiveness of Ipswich’.

Respondent Comment IBC responsetext, which commits the Borough Council topromoting, and enhancing, the viability ofdevelopment in the Town Centre andWaterfront area. Enhancements to thePublic Realm can act as a catalyst to furtherinvestment in the area and the development ofthe many derelict, and empty, sites that detractfrom the town's character. 3. Design Guidance.The Company offers its general support to thedesign guidance for streets and public spacesas set out this section of the document.

4. Identified Projects iii. St Peters Port area.The Company looks forward to working with theBorough Council to bring forward thedevelopment of the St Peter's Port site, in amanner which properly respects the sensitivity,and heritage interest, of Wolsey Gate, StPeter's and St Mary at the Quay churches,together with the listed building at No's I to 5College Street. Whilst the Company's emergingproposals include the enhancement of the north/ south route between St Peter's Street and theWaterfront, it considers that it may be overambitious to try and, effectively, provide threenew pedestrian routes through the site (TurretLane — Foundry Lane: St Peter's Port toDanceEast Square: Fountain Street toDanceEast Square).Three routes through the site, when takentogether with the proposals to improve thesetting of, and the focal points around, StPeter's Church and Foundation Street / St Maryat the Quay, could considerably restrict theamount of development that could be achievedon the site (so threatening its viability). It wouldalso create multiple crossing points, in closeproximity of each other, on College Street,which could potentially be unsafe in advance ofany firm proposals to realign the Star Lanegyratory system.The Company is also concerned about thepotential impact, upon the viability of the site, ofthe proposals to provide new areas of greenspace - adjacent to St Peter's Church, WolseyGate and along the Star Lane boundary.Further information about the viability ofdeveloping the site is set out in therepresentations submitted in respect of the SiteAllocations and Policies Development PlanDocument Review.

The SPD is a design ratherthan an economic developmentdocument, but it embodies theambition of enhanced economicperformance. It is not,therefore, necessary to restatethis within the 9 ‘themes’, whichare concerned with designapproaches.

Key Location Project (iii) StPeters Port. Comments aboutthrough routes and green spacenoted. The recommendationsrefer to the potential within asite, which it may not bepossible to fully realise, due tosite constraints at thedevelopment stage, howeverthe objective of open spacecreation and north-southconnectivity can be achieved inother ways. The Turret Lanealignment is of great historicsignificance; retaining thepotential for a route shouldremain in the SPD.

Respondent Comment IBC response5. Identified Projects: 17. The Companysupports the Council's proposals to make betteruse of this important public space.

4. Identified Projects 18. Foundation StreetSouth. The Company generally supports theproposals for Foundation Street. They must,however, recognise the fact that FoundationStreet will, most likely, provide the main vehicleentrance for any future development of the StPeter's Port site.

Supporting Projects (17)DanceEast Square. Commentsnoted.

Supporting project (18).Foundation Street south.Comment noted, but theemphasis in the SPD willremain. A solution will need tobe found which protects theproposed pedestrian space infront of St Marys Church – it isa potential asset for theredevelopment of St PetersPort as well.

NaturalEngland

While we welcome this opportunity to give ourviews, the topic this Supplementary PlanningDocument covers is unlikely to have majoreffects on the natural environment, but maynonetheless have some effects. We thereforedo not wish to provide specific comments, butadvise you to consider the following issues:Green InfrastructureThis SPD could consider making provision forGreen Infrastructure (GI) within development.This should be in line with any GI strategycovering your area.The National Planning Policy Framework statesthat local planning authorities should ‘ take astrategic approach to maintaining andenhancing networks of habitats and greeninfrastructure; ’. The Planning PracticeGuidance on Green Infrastructure providesmore detail on this.Urban green space provides multi-functionalbenefits. It contributes to coherent and resilientecological networks, allowing species to movearound within, and between, towns and thecountryside with even small patches of habitatbenefitting movement. Urban GI is alsorecognised as one of the most effective toolsavailable to us in managing environmental riskssuch as flooding and heat waves. Greenerneighbourhoods and improved access to naturecan also improve public health and quality oflife and reduce environmental inequalities.There may be significant opportunities to retrofitgreen infrastructure in urban environments.These can be realised through:· green roof systems and roof gardens;

In response to comments aboutgreen habitat networks, greeninfrastructure and biodiversityenhancement, it is agreed thatthis information is absent fromthe SPD, and should beincluded, for instance in relationto the river corridor other greenareas such as churchyards.

Biodiversity and greeninfrastructure paragraph addedto 3.12.

Respondent Comment IBC response· green walls to provide insulation or shadingand cooling;· new tree planting or altering the managementof land (e.g. management of verges to enhancebiodiversity).You could also consider issues relating to theprotection of natural resources, including airquality, ground and surface water and soilswithin urban design plans.Further information on GI is include within TheTown and Country Planning Association’s""Design Guide for Sustainable Communities""and their more recent ""Good PracticeGuidance for Green Infrastructure andBiodiversity"".Biodiversity enhancementThis SPD could consider incorporating featureswhich are beneficial to wildlife withindevelopment, in line with paragraph 118 of theNational Planning Policy Framework. You maywish to consider providing guidance on, forexample, the level of bat roost or bird boxprovision within the built structure, or othermeasures to enhance biodiversity in the urbanenvironment. An example of good practiceincludes the Exeter Residential Design GuideSPD, which advises (amongst other matters) aratio of one nest/roost box per residential unit.Landscape enhancementThe SPD may provide opportunities to enhancethe character and local distinctiveness of thesurrounding natural and built environment; usenatural resources more sustainably; and bringbenefits for the local community, for examplethrough green infrastructure provision andaccess to and contact with nature. Landscapecharacterisation and townscape assessments,and associated sensitivity and capacityassessments provide tools for planners anddevelopers to consider how new developmentmight makes a positive contribution to thecharacter and functions of the landscapethrough sensitive siting and good design andavoid unacceptable impacts.For example, it may be appropriate to seekthat, where viable, trees should be of a speciescapable of growth to exceed building height andmanaged so to do, and where mature trees areretained on site, provision is made forsuccession planting so that new trees will bewell established by the time mature trees die.Other design considerationsThe NPPF includes a number of designprinciples which could be considered, including

Respondent Comment IBC responsethe impacts of lighting on landscape andbiodiversity (para 180).

HistoricEngland

We are pleased, to have the opportunity tocomment on this document at this stage. Thesecomments should be read in conjunction withour previous consultation response, submittedon 26 July 2017. Paragraph 185 of the NationalPlanning Policy Framework (NPPF), is relevant.General CommentsWe welcome the timely production of this SPD,and are pleased to see that the historicenvironment of Ipswich is at the forefront ofconsiderations in this strategy, with its richheritage highlighted in the first paragraph of thedocument. Moreover we appreciate thesentiment it espouses of ‘making the town amore beautiful place’. We would suggest thatthe word ‘heritage’ could be replaced with‘historic’, for a more formal use of language.Para 1.5 - there is a minor typo in thisparagraph: “three key objectives”.We support the three key objectives identifiedin para 1.6, and are pleased to see that one ofthe key outcomes of achieving those objectivesis intended to be a celebration of Ipswich’sheritage. We would suggest, however, that theenhancement of Ipswich’s historic townscapecould be included as a key objective in itself,which could be achieved through the successfulimplementation of positive changes to thepublic realm, improvements to permeability andlegibility etc.We welcome the identification in paragraph 1.8of ‘celebrating Ipswich’s heritage’ as a keybeneficial outcome from achieving thedocument’s three objectives. We also welcomethe intended outcome of strengthening north-south axes across the town to the waterfront.Achieving this outcome would, if implementedappropriately, also reinforce the historiccharacter and urban morphology of this mosthistoric section of Ipswich.Para 1.9 - themesMany of the themes identified will undoubtedlyhave tangential benefits for the historicenvironment, and we are pleased to see theinclusion of improvements to public spacessuch as church yards, as well as the publicrealm in the town centre, included. Given thestated intention of ‘identifying the good "thingsabout Ipswich’, we would welcome furtheremphasis on the potential for improvements tothe historic character of Ipswich within these

1.5. Typo noted. Corrected.

1.6. Comment noted. Theconservation of Ipswich’sunique historic townscape is animportant objective.In response to HE’s comment,the third objective has beenamended to reflectconservation concerns.

1.9. Themes – in response toHE’s comment, the historicreferences in the ‘StrengtheningIdentity’ theme have beenenhanced, and the word‘incidental’ removed from thesecond theme ‘celebratingpublic life’

Respondent Comment IBC responsethemes, perhaps as additional text within‘Strengthening Identity’, given that Ipswich’sidentify is inextricably linked with the town’shistoric environment.Policy ContextIn addition to the legislation already referenced,we suggest that the statutory duties placedupon Local Planning Authorities in Sections 71and 72 of the Planning (Listed Buildings andConservation Areas) Act 1990 should also bereferred to, in support of the proposals.In addition, we would highlight that the NPPFhas recently been updated (February 2019).We would suggest that there are varioussections within the NPPF that it would be worthhighlighting, particularly those found in thesections on design and conserving the historicenvironment.Design GuidanceWe welcome the comprehensive guidancefound in this section regarding the principals ofgood urban design and we are pleased to seethat the best practice found in HistoricEngland’s advice ‘Streets for All’ is evidentthroughout. In particular, we welcome theemphasis on reducing street clutter, minimalsignage, and local distinctiveness on pages 8and 9.We would recommend that, in the section onsurfacing materials on page 12, consideration isgiven to ensuring that where high qualitymaterials are installed they are notsubsequently removed and not replaced duringexcavations for utilities maintenance etc,undermining the benefits.Focus ProjectsIn general, Historic England welcome theseprojects, and consider that overall theirimplementation will result in a positive changeto the historic townscape of Ipswich, particularlywhere programmes of new public realm,decluttering and improved lighting and signagewill create new spaces and routes through thehistoric townscape of Ipswich enhancing thesetting of listed buildings and better revealingthe significance of the conservation area. As ageneral comment, we consider that thelanguage within the packages could be moredefinitive in places, providing more certaintyabout what the council expect to see in certainlocations, rather than simply providingsuggestions as to what ‘could be done’.We do not wish to make detailed comments oneach of the proposed projects, but offer the

Policy Context. Comment notedabout inclusion of Planning(Listed Buildings andConservation Areas) Act 1990,and sections from the NPPF.Additional paragraph (2.6)added to reflect comment.

NPPF – Policy Contextparagraph no. 2.7 addedreferencing the heritageaspects of the NPPF.

Page 12 – surfacing. This issueis addressed in Appendix 2 –Maintenance & Management.

Focus projects. The SPDavoids design masterplanningin order to retain flexibility,given the medium / long timeperiod for which guidance isbeing provided.

Respondent Comment IBC responsefollowing specific comments and queries oncertain key projects.Project i - St Peter’s DockWe welcome this project, and consider that itwill represent an enhancement. Specifically,we’re pleased to see that consideration is givento the unification of the public space with areasfurther east through the use of a coherentpalette of materials. We are also pleased to seethat the area’s maritime heritage will provide anunderpinning theme for works along the water’sedge, which will help reinforce a ‘Waterfront’identity and potentially enhance theconservation area. ""Project ii - Bridge Street gatewayWe concur that this is an important arrival areafor both the Waterfront and Town Centre partsof Ipswich, and that the proposed redesign willresult in some benefits in terms of north-southconnectivity, the area around St Peter’s Dock,and the increased area of open, landscapedspace would be an enhancement to the settingof St Peter’s Church.However, we consider that the project will onlyprovide relatively superficial benefits to thisarea whilst the gyratory remains. In particular,we would question the use of a public seatingarea that faces out onto the busy two lanehighway approaching the roundabout. Weconsider that the brief statement regarding theStar Lane Gyratory is limited in ambition, andthe second sentence, moreover, appears to beincomplete. Please see below for additionalcomments regarding this point.Project iii - St Peter’s Port AreaWe welcome the intention to sensitivelyredevelop the site to the east of St Peters, andare pleased to note that the setting of both thechurch and the Wolsey Gate is referenced. Wewould welcome early discussions with relevantstakeholders regarding detailed designproposals for this area, given the sensitivity ofthis location.Project v - Upper Brook Street/NorthgateWe welcome the general principles of thisproject, but suggest an additional aspirationcould be to reduce the carriageway width, inorder to provide a better environment forpedestrians using the shops and otheramenities along the street. The possibility forstreet trees in this location could also beexplored, if thought appropriate.Project vi - Upper Orwell Street

Project (i) St Peters Dock.Comments noted.

Project (ii) Bridge StreetGateway & Project (iii) StPeters Port Area. Commentsnoted. The provision ofpedestrian spaces alongsidethe junction will be managedthrough closure of the sliproad,which will create space for anenvironmental screen.

IBC and SCC understand thenegative impact of the gyratory,and continue to work togetherto find a long term solutionwhich will enhance thewaterfront setting and improvenorth south pedestrianconnectivity, whilst allowing forefficient vehicle movementeast-west through the towncentre.

(v) Upper Brook St / Northgate.Comment noted. The street ispart of the bus circulation routeand traffic managementcurrently precludes pavementwidening.

(vi) Upper Orwell St. Commentnoted – reference to highquality and distinctive added toSPD.

Respondent Comment IBC responseIn the second bullet point it is unclear what‘special materials’ might be, and suggest thatthe words ‘high quality and locally distinctive’are substituted.Project viii - Princes Street BridgeWe welcome this project, and consider that theunification of public realm, signage and lighting(including the reinstatement of authenticnineteenth century lamps on the bridge itself)will enhance the route between station andtown.Project ix - Arras SquareImproved and consistent public realm aroundthe church of St Stephens is welcomed, subjectto design details, as it will create a sense ofunity and coherence to this area. We arepleased also to note the intention of makingreference to the site’s Anglo-Saxon origins inthe design for new public realm, and considerthat this has the potential for better revealingthe area’s significance."The ‘viewpoint’ indicator for the map on thisproject appears to be incorrectly located.Supporting Projects We suggest that for claritya small map of each of the numberedSupporting Projects could be included to helporientate the reader. Otherwise, we welcomethe general principles that underpin thesesupporting projects, but do not wish to offerdetailed comments for each one. In particular,however, we consider the proposed IpswichTrails (40) to be a positive idea and project thatwill enhance the way people are able to engagewith and appreciate Ipswich’s historicenvironment.The Star Lane GyratoryWe note that the gyratory is briefly mentionedon page 28, but this comment appears vagueand non-committal regarding what should beone of the key considerations of any publicrealm strategy that focuses on the integrity ofIpswich’s historic core and the linkagesbetween the town centre and the waterfront.We appreciate that the gyratory represents along term issue, and that solving the problemsof connectivity it creates will require a long termplan. However, we consider that this SPD lacksthe firm commitment to addressing the issue wewould like to see from a strategic document.We consider that not fully addressing thequestion of the Star Lane Gyratory at this stagewould be a fundamentally missed opportunityfor Ipswich, and undermines the document’sability to achieve its key objectives - i.e.

(viii) Princes St Bridge.Comment noted. The optionsfor bridge parapet lighting mayinclude modern as well astraditional designs, but this willbe dependent on the approachdeveloped.

(ix) Arras Square. Commentsnoted. Correct viewpoint oninset map.

Supporting Projects. Inset mapswill not be necessary, but it maybe possible to repeat theorientation map on page 25, atthe start of the SupportingProjects section.

Star Lane Gyratory. Commentsnoted. See IBC’s response inrelation to project (ii), above.The gyratory is subject tocontinuing review, but IBC donot share HE’s view that acomprehensive reappraisal ofits future, with implications fortraffic movement throughout thetown centre, is a priority.

SCC have been party to theproduction of this documentand have not sought theinclusion of significant changesto the gyratory system.Ultimately the SPD seeks toimprove public spaces, and theenvironmental improvement of

Respondent Comment IBC responseenhancing connectivity, permeability, legibilityand coherence - in the long term.The problems the gyratory causes, includinginhibiting connectivity between the town centreand waterfront for active modes of transport; alack of townscape coherence; the degradationof the setting of listed buildings and thecharacter of both Waterfront and Town Centreconservation areas; and indeed otherenvironmental effects such as air pollution, arecommonly discussed. Although, as notedabove, many of the individual packages ofworks - particularly those in and around thearea of the gyratory - would result inimprovements, the overall benefits of theimprovements in the area affected by thegyratory will be limited and consequentlyIpswich will likely not achieve its full potentialuntil the overarching issue of the gyratory isaddressed.This SPD has the potential to set the agendafor the long term improvement andenhancement of Ipswich’s internal connectivity,and it is the ideal document to begin to set outsome broad strategic intentions with regard tothe gyratory that can be subjected to publicconsultation at an early stage. Ideally thisdocument should be underpinned by athorough, detailed and objective analysis of thegyratory and its impact on movement throughIpswich, using this as an evidence base tosupport the SPDs discussion andrecommendations. However, we recognise thatunless this work has already beencommissioned and carried out, this would resultin a delay to the SPDs adoption that may not bedesirable and therefore in lieu of this, westrongly recommend that a more proactive,ambitious approach is taken. Specifically, wewould recommend that this SPD activelycommits the local authority to commissioning adetailed study into the gyratory and possibleapproaches to its future management as one ofits key recommendations."We would highlight also that there is presentlya renewed focus by Government on potentiallylarge scale and strategic improvements to ourtown and city centres, including for instance theFuture High Streets Fund: The Housing,Communities and Local GovernmentCommittee has also very recently published itsresearch on High Streets and town centres.Appendix 2 - Maintenance

the gyratory is sought through anumber of the projects,including identifying theimprovement of connectivitybetween important spacesacross the SPD area. Anysignificant change to trafficflows, as identified by HE, isbeyond the scope of thedocument. Officers will continueto work with SCC as theHighways Authority withregards to any proposedchanges to the highway.

Respondent Comment IBC responseWe welcome the consideration given toensuring continuity of supply for bespokematerials and their storage (p84). We alsowelcome the consideration given under‘Reinstatement’, on page 85, to ensuring thathigh quality and non-standard materials arereplaced on a like-for-like basis afterinterventions, for example by utility companies.Concluding CommentsIn conclusion, we welcome the production ofthis SPD and consider that the principles andprojects that it proposes to implement arepositive and will, overall, result inenhancements to Ipswich’s historic town centreover the medium to long term.

Concluding Comments. Noted.

Savills onbehalf ofABP

The SPD area covers the town centre andincludes the Wet Dock and Island site, whichcomprise parts of ABP’s land ownership. AsIBC is aware, the Island Site is allocated forcomprehensive development as Site IP037.

ABP is supportive of the general aims of thethree projects which are relevant to itslandholding at the Island Site and in thesurrounding area, namely:i. St Peter’s Dock (a ‘Key Location Project’)25. Waterfront – North Side (an ‘othersupporting project’)40. Discover Ipswich Trails – Maritime Heritage(a ‘potential future link’)However, where IBC seek contributionstowards the realisation of these projectsthrough CIL and s106 obligations, suchcontributions should be reasonable andproportionate to the development proposed andshould not jeopardise the commercial viabilityof the scheme being promoted (consistent withPolicy CS17 - see particularly paragraph 8.199- of the adopted Local Plan). This is particularlycritical in respect of the Island Site given theexisting constraints of the site and therecognised need for the redevelopment of thesite to address these constraints in aeconomically viable and deliverable manner.In particular, we note the reference in respect ofProject i. St. Peter’s Dock to the “potential tocreate wooden boardwalk over water betweenAlbion Quay and New Cut East, potentiallystepping down to water level from the road” and“In long term investigate the feasibility of a newpedestrian and cycle bridge between FoundryLane and Whip Street which reinstates thishistoric connection”. The impact of constructionover the navigable waters of the Wet Dock and

Officers are glad that ABP as amain landowner are supportiveof this SPD. Where financialcontributions are sought theywill need to pass the tests asset out in the CommunityInfrastructure Levy Regulations2010, in that they must benecessary to make thedevelopment acceptable inplanning terms, directly relatedto the development, and fairlyand reasonably related in scaleand kind.

The governments NPPF setsout that individual site viabilitywill be assessed at the time ofactual applications. It is up tothe applicant to demonstratewhether particularcircumstances justify the needfor a viability assessment at theapplication stage.

The projects identified withinthe Public Realm Strategy SPDidentify where potential forimprovements to public spacecan be made. The deliverabilityof the projects themselves, aresubject to feasibility andlandowner/stakeholderinvolvement. Wheredevelopment is forthcoming aspart of wider regenerationprojects such as the Island Site,or in isolation, the respective

Respondent Comment IBC responsea crossing of the New Cut are matters whichABP will need to scrutinise carefully and wouldexpect to be involved in respect of its statutoryduties as a harbour undertaker.

statutory consultees will beconsulted at the appropriatetime.

SCC SeniorArchaeologyOfficer

The potential is exciting, especially forarchaeology/heritage elements but also moregenerally as a resident. There might be a needto mitigate tree pit holes in some places.The following sites would benefit fromdiscussion of/mitigation for planting wheredeeper areas may be proposed, as areas ofarchaeological sensitivity – although a note in3.12 that archaeology should also beconsidered when schemes are developed mightcover them all?ii) Bridge St Gateway, vii) Regentgateway/Major’s Corner, xi) St Mary le Tower,15) Cromwell Square, 21) St Michael’s Church,22) St Margaret’s Green, 36) St Matthew’sChurchyard, 37) St Mary at the Elms.

Comment noted. As suggested,a ‘Consider Archaeology’subheading within 3.12 ‘UrbanPlanting’, provides a singlecomment covering all sites. Refto archaeology SPD alsoinserted in Policy section.