Borough Council Local Development Framework

Statement of Consultation on Proposed Focused Changes to the Core Strategy and Policies Development Plan Document

November 2010 – January 2011

Planning, Transport and Regeneration Ipswich Borough Council Grafton House 15-17 Russell Road Ipswich IP1 2DE Tel: 01473 432019 Web: www.ipswich.gov.uk Email: [email protected] Contents

1. Introduction 3

2. Background 3

3. Persons or bodies invited to make representations 4

4. Consultation techniques used by the Council 5

5. Conclusion 6

Appendices

1. LDF Mailing List 7

2. Letters sent to stakeholders 18

3. Advertisements placed in local press 21

4. Article published in the December 2010 Angle 25

5. Notes of public meeting 26

6. Notes of Discussion Group 29

2 1. Introduction

1.1 On Monday 15th November 2010, Ipswich Borough Council published for public consultation Proposed Focused Changes to the submitted Core Strategy and Policies Development Plan Document.

1.2 This Statement of Consultation describes:

 which bodies and persons Ipswich Borough Council as local planning authority invited to make representations on the Proposed Focused Changes; and

 how those bodies and persons were invited to make representations.

1.3 A separate document called the Summary of Main Issues Raised in Representations, February 20111, provides a summary of the representations received to the Proposed Focused Changes and the main issues raised through them.

2. Background

2.1 The East of England Plan was published in May 2008 and provided the context for the preparation of the Ipswich Core Strategy. It set out the housing and jobs targets for Ipswich Borough and the basis for cross boundary working within the Ipswich Policy Area, which reflects the extent of the urban area rather than the Borough, and includes land in neighbouring districts2. The Proposed Submission Core Strategy was published for consultation in October 2009 and submitted to the Government with minor amendments on 26th March 2010.

2.2 Examination of the Core Strategy commenced upon its receipt by the Government and the appointment of an independent Inspector, Frances Mahoney DipTP, MRTPI, IHBC. Examination hearings were scheduled for July and September 2010, and a Pre-Hearing Meeting for 15th June 2010.

2.3 However, on 27th May 2010 the Secretary of State announced that he planned to rapidly abolish regional strategies and return decision making powers on housing and planning to local councils.

2.4 On 9th June 2010 the Programme Officer wrote to the Council to suggest deferring those hearings relating to Regional Spatial Strategy (RSS) issues until further clarity had been provided by the Secretary of State. It was agreed to postpone all hearings until September. The scheduled Pre-Hearing Meeting was held instead as an Explanatory Meeting to update interested parties on the process and publicise draft matters, issues and questions.

2.5 On 6th July the revocation of regional strategies was announced and guidance issued to councils on how to proceed3. The Council wrote to the Programme

1 Summary of Main Issues Raised in Representations, Ipswich Borough Council, February 2011. Core document library reference PCD41. 2 East of England Plan, Government Office for the East of England, May 2008, page 32 policy H1, page 20 Policy E1, page 89 para 13.28. Core Document Library reference RCD01 3 Letter to Chief Planning Officer 6th July 2010 from Steve Quartermain Chief Planner including questions and answers guidance. Core Document Library reference PCD25.

3 Officer on 22nd July indicating that September would be the earliest opportunity for the Council to consider the way forward. As a result, on 30th July 2010 the Inspector suspended the Core Strategy Examination for five months to allow time for the Council to consider its options.

2.6 The Council decided on October 27th to continue with a strategy of jobs-led growth for Ipswich, but to adjust housing targets to reflect local evidence. As a consequence of this decision, public consultation was necessary. The Council proposed an eight-week period of public consultation on the Proposed Focused Changes, starting by Monday 15th November 2010 and ending on Friday 7th January 2011. The Council wrote to the Programme Officer on 1st November to inform the Inspector of the decision.

2.7 On 4th November 2010 the Programme Officer responded to the Council on behalf of the Inspector:

“The Council’s proposed consultation process on the focused changes comprises a mix of consultation techniques including:  Letters to stakeholders;  Advertisements in Local Press;  An article in the December Angle;  Use of the Council’s web site;  Letters to those included on the Local Development Framework database (including those that replied at the last major consultation).

In the circumstances of the nature of the focus changes, this seems to be an appropriate strategy for presenting the changes in the public domain. Should the process prompt representations from parties who have not previously been involved in the Examination the Inspector considers these representations should be accepted subject to them being solely in connection with the advertised changes.

It is noted your intention to carry out an 8 week period of consultation which would include the Christmas break. In these circumstances an added week to the consultation period would be in the spirit of fairness and transparency. “

2.8 The Council responded by extending the consultation period to nine weeks, from Monday 15th November 2010 to Monday 17th January 2011.

3. Bodies and persons invited to make representations

3.1 The Council maintains a database of organisations and individuals who have an interest in the Local Development Framework process. It includes both organisations which the local planning authority is required to consult as set out in the Town and Country Planning (Local Development) (England) Regulations 2004 (as amended) (‘the Regulations’), and other organisations and private individuals who have previously engaged with the Local Development Framework process or asked to be kept informed about it.

3.2 The broad categories of consultees included on the database are as follows:  Specific consultation bodies (which includes mainly statutory consultees, for example utilities undertakers, County Council, and adjoining district and parish councils);

4  General consultation bodies including voluntary bodies, and bodies representing the interests of businesses, racial or ethnic groups, faiths, and disabled people;  Other groups and organisations, for example education establishments and environmental groups;  Businesses located within, or with interests in, the Borough; and  Private individuals.

3.3 The organisations are listed at Appendix 1.

3.4 The Council also has in place an adopted Statement of Community Involvement, which in Appendix 3 identifies broadly the consultation bodies to be contacted in relation to development plan document consultations4. The Council complied with the requirements of the Regulations and the Statement of Community Involvement in inviting bodies and persons to make representations on the Proposed Focused Changes to the Core Strategy.

4. Consultation techniques used by the Council

4.1 The Council published four documents for consultation on 15th November 2010:  A schedule of Proposed Focused Changes to the submission Core Strategy and Policies DPD (including revised Tables 3 and 4);  A Sustainability Appraisal Addendum;  An update to the Appropriate Assessment; and  A topic paper called ‘Reviewing the Ipswich Housing Figures’.

4.2 Two additional documents were published for information only; the first was a schedule of proposed minor amendments to the submission Core Strategy and Policies DPD. The second was a version of the Core Strategy document showing all three sets of amendments as tracked changes:  Proposed Minor Amendments approved on 17th March 2010 prior to submitting the plan;  Proposed Focused Changes approved on 27th October 2010; and  Proposed Minor Amendments approved on 27th October 2010.

4.3 The Council used a range of techniques and approaches to publicise the Proposed Focused Changes to the submission Core Strategy and Policies DPD, make the documents available for inspection, and invite representations. a. Letters to all stakeholders as required by the Regulations (including documentation as appropriate) and others as included on the LDF database (sample letters included at Appendix 2); b. Advertisements in the local press (see Appendix 3); c. An article in the December issue of the Council’s newspaper, the Angle (see Appendix 4); d. Information on the Council’s web site (accessible through a ‘friendly’ url www.ipswich.gov.uk/corestrategyexamination and also advertised on homepage); and e. Information and documentation placed at key venues around the Borough, including the Customer Services Centre at the Town Hall, the reception desk at

4 Statement of Community Involvement, adopted September 2007, IBC, page 41 Appendix 3. Core Document Library reference ICD05.

5 the Council’s offices at Grafton House, and the County Library in Northgate Street, Ipswich.

4.4 The Council did not consider that the fullest range of potential consultation events was appropriate for the Proposed Focused Changes, as the changes to the Strategy were not substantial and were likely to mainly be of interest to those already involved in the process. Also, experience during the submission stage consultation under Regulation 27 indicated that numbers attending public meetings was relatively low.

4.5 However, a range of events was organised to provide stakeholders with opportunities to find out more, discuss the Proposed Focused Changes, or express views. This accorded with commitments in the Council’s Statement of Community Involvement about which consultation techniques would be used for which planning documents5.

4.6 public meeting was organised to ensure that interested parties had an opportunity to discuss publicly issues arising, and question Council staff. This took place on Wednesday 24th November 2010 and the notes of the meeting are attached at Appendix 5.

4.7 The Council held a ‘Drop In’ event, which allows people to come to discuss matters informally on a one to one basis with planning staff. This was held on Thursday 6th January 2011 between 12:30 -13:30 and 16:00 -18:00 in the Council Chamber of Ipswich Town Hall and four people attended.

4.8 A discussion group was held for stakeholders from key agencies and the development sector, based on previous involvement in the Strategic Housing Land Availability Assessment. It was held on Thursday 6th January 2011 at 2pm, the notes of the discussion are attached at Appendix 6.

5. Conclusion

5.1 The Council complied with the Regulations and its own Statement of Community Involvement in conducting public consultation on the Proposed Focused Changes, between 15th November 2010 and 17th January 2011. The Council also considers that the consultation strategy pursued was appropriate and proportionate, and provided a variety of opportunities for engagement.

5.2 A total of 94 duly made representations were received to the consultation. The main issues they raised are described in a separate report6.

5 Statement of Community Involvement, adopted September 2007, IBC, page 24, Table 2. Core Document Library reference ICD05 6 Summary of Main Issues Raised in Representations, IBC, February 2011. Core Document Library PCD41.

6 Appendix 1 Mailing List of Organisations on Council’s LDF database

7 Regional Bodies Rushmere St Andrew Parish Council Cityspace Ltd Sproughton Parish Council COLT Telecom Group plc East of England Development Agency Tuddenham St Martin Parish Council Easynet Ltd East of England Local Government Westerfield Parish Council Equant UK Ltd Association Wherstead Parish Council Fujitsu Services Government Office for the East of England Witnesham Parish Council Gamma Telecom Global Crossing (UK) Telecommunications Ltd Health Organisations Adjoining Planning Authorities Hutchison 3G UK Ltd Central Suffolk Primary Care Trust Internet-Central Ltd Babergh District Council East of England Strategic Health Level 3 Communications Mid Suffolk District Council Authority MCI WorldCom Ltd Suffolk Coastal District Council Ipswich Hospital NHS Trust MLL Telecom Ltd Suffolk County Council Ipswich Primary Care Trust Mobile Operators Association Local Health Partnerships NHS Trust Mono Consultants Ltd Parish Councils National Health Service NEOS Networks Norfolk, Suffolk & Cambridgeshire Newnet plc Akenham Parish Council Strategic Health Authority NTL UK Belstead Parish Council Regional Public Health Group Bramford Parish Council O2 Airwave Suffolk (PCT) NHS Brightwell, Foxhall & Purdis Farm Parish O2 plc Suffolk Mental Health Partnership NHS Council Opal Telecom Trust Claydon & Whitton Parish Council Orange Business Services Suffolk Primary Care Trust Copdock & Washbrook Parish Councils Pipex Freston Parish Council Reach Europe Great Bealings Parish Council Police Redstone Henley Parish Council Suffolk Constabulary THUS plc Little Bealings Parish Council Communication service/ apparatus Tiscali UK Ltd Parish Council providers T-Mobile (UK) Ltd Pinewood Parish Council Anglia Telecom plc Torch Communications Ltd Playford Parish Council BT Group plc UK Broadband Ltd

8 Vectone Services Ltd Department for Work & Pensions Interest Groups & Voluntary Bodies Vodafone Ltd Department of Culture, Media and Sport Department of Environment, Food and Alzheimer’s Society Rural Affairs Utilities undertakers (Gas, Sewage, Amateur Swimming Association English Heritage Water, Electricity) Back Hamlet Ipswich, Allotment Holders Environment Agency Association Anglian Water Forestry Commission Belstead Allotments Anglian Water Services Ltd Health and Safety Executive (East Campaign for Better Transport (Ipswich British Energy Group plc Anglia) and Suffolk group) British Gas Highways Agency Campaign to Protect Rural England British Gas Trading Ltd H M Customs and Excise Castle Hill Allotment Field Committee E.On UK Plc Home Office Chamber of Commerce EDF Energy Homes and Communities Agency Essex and Suffolk Water Company Ministry of Defence Headquarters Country Land and Business Association National Grid Company PLC Wattisham Station Cycle Ipswich National Power plc Natural England Dyslexia Association Tendring Hundred Water Services Ltd Network Rail East Suffolk MIND Office of Government Commerce Farming and Wildlife Advisory Group Office of Rail Regulation Federation of Small Businesses Government Departments/ Agencies Sport England - East Region Freight Transport Association Coal Authority, Planning and Local UK Border Agency Friends of the Earth Authority Liaison GeoSuffolk Commission for Architecture and Built Home Builders Federation Environment Inland Waterways Association Defence Estates Ipswich Allotment Holders Association Defence Estates Head Office Ipswich Blind Society Defence Estates Operation North Defence Estates Safeguarding Department for Communities & Local Government Department for Transport

9 Ipswich CVS Suffolk Association of Architects Community Groups (including Ipswich & District Group Ramblers Suffolk Association of Voluntary religious & ethnic groups) Association Organisations Alan Road Methodist Church Ipswich & District Landlords Association Suffolk Biodiversity Partnership Bacton Gospel Hall Trust Ipswich and Suffolk Council for Racial Suffolk County Scout Offices Equality Suffolk Deaf Association Bangladeshi Support Centre Ipswich Archaeological Trust Suffolk Preservation Society Bethesda Baptist Church Ipswich Disabled Advice Bureau Suffolk Rights of Way Ltd Bethesda Community Charitable Trust Ipswich Dock Railway Preservation Suffolk Wildlife Trust Bramford Road Methodist Church Society Sustrans Ipswich in Bloom Cauldwell Hall Road Baptist Church Transport 2000 Ipswich Hospital Bowls Club Chinese Association Woodland Trust Ipswich Model Engineering Society Chinese Welfare and Support Christ Church United Reformed/ Baptist Ipswich Ramblers Association Church Ipswich Society Christian People’s Alliance Ipswich Wildlife Group Church of England Landseer/Nacton Road Action Group Dales Residents Association Lawn Tennis Association Friends Families and Travellers London Road Allotment Holders Gujarati Association Maidenhall Allotment Holders Gypsy Council Mental Health Volunteer Scheme Homer Defoe Residents Association Newton Road Conservative Club Indian Association Northgate & Colchester Road Allotments Ipswich and District Irish Society Ramblers ’Association Ipswich and Suffolk Indian Association Northern Fringe Protection Group Ipswich Bangladeshi Mosque River Action Group Ipswich Caribbean Association RSPB Ipswich Caribbean Association (Dominos RSPB Eastern Office Club) Save Our Country Spaces Ipswich Community Radio Shelter Ipswich Hindu Samaj Suffolk Amphibian & Reptile Group

10 Italian Association Ukrainian Association Austin-Smith Lord Jehovahs Association Waterfront Churches AWG Land Holdings Ltd Jehovahs Witnesses Wherstead Road Residents Association B & F Mechanical Kesgrave Baptist Church Whitton Residents Association B&Q Maidenhall Tenants’Association Witnesham Parochial Church Council Babtie Group Nacton Priory Court Residents Yugoslavian Association Bairstow Eves Ltd Association Bank of Scotland Neptune Square Residents’ Association Businesses Barclays Bank PLC Orchard Residents Association 1st Source Ltd Barefoot and Gilles Orwell Church Barrett Eastern Counties Polish Association ABC LTD Barton Willmore Quakers ACC SYS Software Ltd Barton Willmore Planning Partnership Ravenswood Residents’ Association Adams Holmes Associates Midlands Seventh Day Adventist Church Adaptainer Bellway Homes Limited Shiloh Pentecostal Fellowship adpltd Beroy Architects Sikh Community Centre Allied Property and Leisure Ltd. BHS Ltd Sikh Temple Alsop Verrill Bidwells St John’s Church of England Alstons (Cabinets) Ltd Bidwells on behalf of Norman Agran St Mary le Tower Church Andrew Martin Associates Bidwells on behalf of University Campus St Matthew’s Church Anglo Norden Ltd Suffolk St Pancras Catholic Church Apollo Capital Projects Bill Wilson Planning Ltd Stoke Park Residents Association Apple Kirk Properties Ltd Birketts LLP Stone Lodge Youth Club Archant Properties Limited Blocking Services Ltd The Showmen's Guild of Great Britain - Archial Architects BNP Paribas Real Estate Norwich & Eastern Counties Section Asda Stores Ltd Bolton Aerospace Limited Ashfield Land Boreham Consulting Engineers Ashton Graham Bowerwood Ltd ASP Box Commercial Property Services Associated British Foods plc Boyer Planning Ltd Associated British Ports Braceforce Properties

11 Breton Chartered Surveyors Crest Nicholson Eversheds LLP Brett Group Crest Nicholson (Eastern) Ltd EWS Chartered Surveyors Bretts of Ipswich Crown Brolac Fairline Boats plc Brian Park Camping Ltd Cushman & Wakefield Healey & Baker Fairview New Homes Ltd Brimble, Lea & Partners Cut It! Style It! Fenn Wright Broadway Malyan Planning D Moyes and Son First Buses Ltd - Eastern Counties Brown & Co David Brown & Co Firstplan Bryant Homes Ltd David Clarke & Associates FIS Windows Ltd Bullworthy Shallish LLP David Hicken Associates Ltd Flitterman Investments Ltd Buttermarket Shopping Centre David Lock Associates FLOvate Workflow Technologies Ltd Carter Jonas David Walker Chartered Surveyors FPD Savills Cedar Harp Ltd David Wilson Estates Fuller Peiser Chartered Town Planning Consultant Davies Arnold Cooper Fusion Online Limited Chelsteen Homes D C Bells Fynn Valley Golf Club Chris Thomas Ltd Debbage Yachting G L Hearn Churchill Insurance Delta (MB) Ltd G L Hearn Planning Churchmanor Estates Company Plc Development Planning Partnership G.W. Commercial Tyres Ltd CINRAM (UK) Ltd DevPlan Gainsborough Retail Park Circle Anglia Ltd Devplan UK Galley Restaurant City Grill Dialogue GE & GW Stennett Ltd Cliff Road Developments Ltd Don Proctor Planning Geo Wimpey plc Cobbetts Solicitors DPDS Consulting Group Getech Ltd Corpra Drivers Jonas GL Hearn Colin Girling & Co Ltd DTZ Consulting and Research Gladstone Homes Ltd Colliers CRE East Anglian Bearing Service Ltd Glaswells Comet East Anglian Daily Times GLP Properties Compair (UK) Ltd East Anglian Wire Works Glyn Hopkin Limited Countrywide Surveyors East of England Co-operative Society Ltd Goddard & Co (East Anglia) Ltd CountyWeb Ltd English Welsh & Scottish Gotelee and Goldsmith Crane Ltd English Welsh & Scottish Railway Ltd Greystoke & Everleigh Ltd

12 GVA Grimley Ipswich Town Football Club Lambert Smith Hampton Halfords plc IS Logistics Ltd Land and Property Consultant Harris Lamb Planning consultancy Isaac Lord Landmark Information Group Ltd Harwich International Port J B Planning Associates LDA Design Heart FM J J Wilson (Ipswich) Ltd LaSalle Investment Management Heating Replacement Parts and Controls J S Bloor (Sudbury) Ltd Lawson Planning Partnership Ltd Heaton Planning Ltd J Sainsbury PLC Learning and Skills Council Helical Retail Ltd J T Elvin Ltd Lennon Planning Ltd Hertz Rent A Car Jack White Organs Levvel Higgins Homes Ltd Jackson Civil Engineering Lidl UK GmbH Holden Timber Jacobs Lister Locks Ltd HOMA DESIGN LIMITED James Aldridge Littman Robeson Hoopers Architects Ltd January's Lorrimar Investments Hopkins Homes Limited Jewson PLC MVA Howe and Silver JG Land and Estates Limited Martin Robeson Planning Practice Hutchinson Ports (UK)Ltd JG Stoke Quay LLP McCarthy & Stone Developments Ltd Hyder Consulting (UK) Ltd JJ Wilson (Ipswich) Ltd McDonalds Ian Dickson Ltd John Field Consultancy Mears, Hobbs and Durrant Icosys Computers & Communications John Harrison Mediterranean Shipping Company (UK) Ltd John Lyall Architects Limited IDEA Ltd John Newton Associates Merchant Projects (Ipswich) Ltd Il Punto John S Cohen Foundation Mersea Homes Ltd Indigo Planning Ltd Jones Lang LaSalle Messrs S E Kent & Son Inventures JSM Property Management Ltd Mono Consultants Ltd Ipswich Building Society KeConnect Systems Ltd Moult Walker Ipswich Buses Ltd Kent Blaxill Mr N Agran Ipswich Computer Services Kesgrave Covenant Ltd N L J Associates Ipswich Port Ltd KLH Architects Nathaniel Lichfield & Partners Ladbroke Limited National Car Parks Ipswich Sports Club Lafarge Aggregates Ltd NatWest Bank Ltd

13 Neptune Café Pullman Development Ltd Savills Neptune Marina Ltd R Building Maintenance Scott-Brown Partnership Network Analysis, Network Strategy R G Carter (Ipswich) Ltd SCS Ltd Norfolk & Suffolk Estates Ltd R W Bond Sea Containers Property Services NWA Planning Raglan Housing Association Ltd Seawheel Ltd O B O Scaffold Co Ltd Ramblers' Association Securicor Omega Express Orchid Properties Ranelagh Primary School Servite Houses Orwell Motorcycles Ltd Ransomes plc Seven Project Management Orwell Pine Company Ltd Rapleys LLP Shearer Property Group Limited Orwell Veterinary Group RBS Insurance Sina Developments P & O Ferrymasters Ltd Redrow Homes (South East) Ltd Skinner Salter Partnership P & O Trans European (Holdings) Ltd Regeneration Holdings Smart 421 Paul & Company Richard Jackson Partnership Ltd Smart Planning Ltd Peacock & Smith Ltd Richards Speedy Hire Peecock Short Ltd Riga Properties Ltd Spenhill Regeneration Ltd Pegasus Planning Group RJM Engineers Spurdens Newsagents Pennington Chartered Surveyors RMJM St Clements Golf Club Persimmon Homes (Essex) Robinson and Hall LLP Stanley Bragg Partnership Ltd Peter Colby Commercials Ltd Robottom Developments Ltd Steele & Co Phillips Planning Services Ltd ROC Associates Stirling Maynard Transportation PKF (UK) LLP Roche Chartered Surveyors Stocks Funfair Planning Potential Roger Tym &Partners Strategic Land and Planning Consultants PMP Plus Roxburgh Roofing Strutt & Parker Port of Felixstowe Royal & Sun Alliance Sturgis & Co Architects Post Office Property Holdings RPS Chapman Warren Suffolk Building Services Ltd PRC Fewster RPS Planning Terence O’Rourke Planning Priory Park Ltd Ryan Elizabeth Holdings Tetlow King Planning Prudential Pensions Ltd Saracens House Business Centre The Barton Willmore Planning PRUPIM S Sacker (Claydon) Ltd Partnership PSG Sainsbury's Supermarkets Ltd The Fairfield Partnership

14 The Grove (Ipswich) Management Co Other groups or organisations East of England Co-operative Society Ltd Ltd Abbeyfield Orwell Society Eastern Landlords Association The John Russell Gallery English Churches Housing Group Amberfield School The Landscape Partnership Faculty of Social Sciences Anchor Trust The Planning Bureau Ltd Flagship Housing Group Ltd Anglia Care Trust The Swan Forest Heath District Council Anglia Housing Association Group Trustees of the PE Cooke Settlement Genesis BBC Look East Turley Associates Green Party BBC Radio Suffolk Turnstone Estates Greenways Countryside Project Bethesda Baptist Church Universal Tyres Gusford County Primary School Britannia Primary School V A Marriott Ltd Gypsy Council Broadland Housing Association Van Ommering Tank Terminal Habinteg Housing Association Broke Hall County Primary School Victoria Nurseries Halifax Primary School Burlington Primary Care W D Coe Ltd Handford Hall Primary School Castle Hill Junior School W S Atkins Hanover Housing Association Cephas Comminity Care WSP UK Headway Ipswich and East Suffolk Chantry High School W Y G Planning Her Majesty's Court Service Cliff Lane Primary School Walker Morris Hereward Housing Clifford Road Primary School Ward & McKenzie Ltd Hillside County Primary School Coastal Housing Action Group West and Partners Holywells High School Colchester Borough Council WH Smith Ltd Homeless PMS Team Commissions East Willis Limited House of Commons Wimborne Estates Ltd Communities and One-Ipswich LSP Manager Housing 21 Wimpey Homes Community Education Iceni Homes Ltd Wincer Kievenaar LLP Connexions Suffolk ICENI Project Winsor Clarke Brackenbury Ltd Co-op Homes Services Invest East of England Witnesham Sawmills Ipswich & District Citizens Advice Bureau Zephyr Security CSV Media Clubhouse Ipswich & Norwich Co-operative Society Ipswich & Suffolk Council for Racial Dale Hall County Primary School Equality East England Arts

15 Ipswich Buses Ltd Northgate High School St John Ambulance Ipswich Borough Council Labour Group Orbit East St John's CEVAP School Ipswich Central Orbit Housing Association St Joseph's College Ipswich Charioteers Wheelchair Football Orchard Street Health Centre St Margaret's CEVAP School Club Ormiston Children and Families Trust St Mark's Catholic Primary School Ipswich Disabled Advice Bureau Orwell Housing Association St Mary's Catholic Primary School Ipswich High School Otley College St Matthew Housing Ipswich Housing Action Group Pensions Service St Matthew's CEVAP School Ipswich Institute Planning Inspectorate St Pancras Catholic Primary School Ipswich Partnership Presentation Housing Association Ltd Stoke High School Ipswich Preparatory School Raglan Housing Association Ltd Stone Lodge Youth Club Ipswich School Ranelagh Primary School Stonham Housing Association Ipswich Sports Club Ravenswood County Primary School Suffolk ACRE Ipswich Transport Museum Refugee Council Suffolk Association of Local Councils Ipswich Women's Aid Rose Hill Primary School Suffolk Association of Voluntary Ipswich YMCA Royal Town Planning Institute Organisation Jephson Housing Association RTPI East of England Suffolk Chamber of Commerce Jobcentreplus Rushmere Hall Primary School Suffolk Coast & Heaths AONB Salvation Army Housing Association Suffolk Development Agency London & Quadrant Housing Association Sanctuary Hereward Suffolk East Federation of Women's Institutes Marine Conservation Sanctuary Housing Association Suffolk Education Business Partnership Mind Charity Shop Saracen's House Business Centre Suffolk Fire Service Morland Primary School Sidegate Lane Primary School Suffolk GP Services Murrayfield Primary School SOLO Housing Suffolk Heritage Housing Association National Farmers' Union Springfield Infant School and Nursery Suffolk Housing Society National Housing Federation Springfield Junior School Suffolk Learning Partnership National Playing Fields Association Sprites Primary School New Wolsey Theatre St Albans Catholic High School Suffolk School of Samba Norfolk and Suffolk Probation Trust St Edmundsbury Borough Council Suffolk Strategic Partnership Northgate Foundation St Helen's Primary School

16 Suffolk Supporting People Suffolk Trust Suffolk Young Farmers Swan Housing Association The Grove (Ipswich) Management Co Ltd The National Trust The Oaks County Primary School The Riverside Group The Royal British Legion The Theatre’s Trust The Willows Primary School Thomas Wolsey School Thurleston High School Tree House Family Forum Tree House Sure Start Children's Centre Unite the Unions University Campus Suffolk Warden Housing Association Waveney District Council Westbourne High School Wherry Housing Association Whitehouse Community Infants School Whitehouse Junior School Whitton County Primary School Willow Park Montessori Day Nursery

17 Appendix 2 Sample consultation letter

18 our ref SB/CB Specific your ref - please ask for Cheryl Bacon direct dial 01473 432019 email [email protected]

11th November 2010

Dear Sir/Madam,

The Ipswich Local Development Framework: Core Strategy and Policies Development Plan Document (DPD) Proposed Focused Changes to a Regulation 30 Submission DPD (Town and Country Planning (Local Development) (England) (Amendment) Regulations 2008)

Following revocation of regional spatial strategies and the suspension of the Examination in Public of the Core Strategy and Policies development plan document on 30th July 2010, I am writing to let you know that the Council has published its Post Submission Schedule of Proposed Focused Changes to the Core Strategy and Policies DPD for the future planning of Ipswich. The Council is seeking comments on the soundness of the Proposed Focused Changes prior to the Examination in Public resuming.

This formal consultation, which begins at 9am on Monday 15th November, seeks your views by 5pm on Monday 17th January 2011. Comments received beyond this date cannot be considered. The consultation period has been extended to nine weeks to take account of the Christmas break. In order for the Government’s Planning Inspector to take your comments on the Proposed Focused Changes into account at the examination, it is essential that you make a representation at this stage.

Ipswich Borough Council is inviting representations on the Proposed Focused Changes, but not on the submitted Core Strategy itself.

The following documents are enclosed for your information:

1) Schedule of Proposed Focused Changes for comment. 2) Sustainability Appraisal addendum report November 2010 3) Updated Appropriate Assessment report November 2010 4) Schedule of minor amendments for your information only. 5) Topic paper ‘Reviewing the Ipswich Housing Figures’.

A tracked changes version of the Proposed Submission Core Strategy and Policies development plan document is also available to view via the Council’s website, www.ipswich.gov.uk/corestrategyexamination and at the venues mentioned in the formal notice, which is also enclosed.

19 The formal notice enclosed indicates when and where the documents are available for inspection and how to submit representations about them. You are urged to make representations via the consultation module on the Council’s website where possible. This would greatly assist the prompt processing of your comments. A paper comment form is downloadable from the webpage.

You are invited to attend a public meeting to be held on Wednesday 24th November at 7pm at the Council Chamber in the Town Hall.

Yours faithfully,

Mike Tee Head of Planning, Transport and Regeneration

Please note: the proposed submission versions of the other two main components of the Local Development Framework - the Site Allocations and Policies [which will put forward where sites should be allocated for particular uses outside central Ipswich], and the IP-One Action Area Plan [which will propose where development should take place in the Town Centre, Waterfront, Education Quarter and Ipswich Village] - will be prepared in 2011.

20 Appendix 3 Advertisements from the Local Press

21 22 Evening Star 31/12/10

E.A.D.T 31/12/10

23 Evening Star 18/03/11

24 Appendix 4 Extract from the Angle Newspaper

25 Appendix 5 Notes of Public Meeting Held on 24th November 2010

Proposed Focused Changes Public Meeting

Date: Wednesday 24th November Time: 7pm Venue: Town Hall

Chairman: Councillor Richard Atkins, Ipswich Borough Council Presented by: Russell Williams – Chief Executive, Ipswich Borough Council

Attendees: Sarah Barker – Principal Planner, Ipswich Borough Council Robert Hobbs – Senior Planner, Ipswich Borough Council Damini Bhan – Planner, Ipswich Borough Council Cheryl Bacon – Planning Administrator, Ipswich Borough Council Rebecca Greasley – Student Planner, Ipswich Borough Council Councillor Carole Jones, Ipswich Borough Council Councillor Jeanette Macartney, Ipswich Borough Council Councillor John Mowles, Ipswich Borough Council Tibbs Pinter, Ipswich Borough Council Steve Grimwood Geoffrey Dyball, Fenn Wright Annie Ruffell, Kesgrave Covenant Limited

Programme

Welcome Russell Williams, Sarah Barker and Robert Hobbs welcomed members of the public and councillors. Those in attendance were asked their individual issues and to ensure that these were raised during the presentation.

Presentation Russell Williams gave a presentation to the members of the public and the councillors on the progress that Ipswich Borough Council has made so far. He then went into more detail about the focused changes that have been made to the Core Strategy, and finally where Ipswich is at now.

Questions Councillor Atkins then announced that the floor was open for questions.

Question 1) Councillor Jones: ‘When will the Northern Fringe figures be reviewed?’ Russell Williams answered: How quickly these will be determined is a difficult question to answer. We need to get the Core Strategy through adoption first. There are lots of political issues involved.

Thanks and close Russell Williams thanked the members of the public for their support and Councillor Atkins formally closed the meeting.

26 The process so far Core Strategy and Policies – and Options 2006-07Issues

Proposed Focused Changes Options Consultation January to March 2008Preferred

Russell Williams, Chief Submission October to November 2009Proposed Executive, Ipswich Borough Consultation March 2010Submission Council om n e p n sbi s oEaiainof soundness commenced upon submissionExamination 24th November 2010

Changes at National Level Examination Suspended

• May 2010 new Government formed • 6th July 2010 regional strategies were revoked (including • End May 2010 Secretary of State announced his intention to housing and economic strategies also) revoke ‘regional strategies’ • 30th July 2010 the Inspector, in consultation with the • (Regional Spatial Strategy dictated the number of homes and Council, suspended the Core Strategy Examination until jobs Ipswich was to provide through the Core Strategy) 31st December 2010 • Ipswich Core Strategy Examination hearings were postponed • Enabled the Council to consider the implications of losing to September pending further ministerial announcements Regional Spatial Strategy

Proposed Focused Changes The Proposed Focused Changes 1

• Council now proposing ‘focused’ changes to • Jobs-led growth strategy retained, but … the Core Strategy and Policies plan • Housing target for 2001 to 2021 reduced • Focused means they affect certain policies or from 15,400 to 14,000 proposals but not the overall strategy or approach • Northern Fringe infrastructure requirements to development strengthened and a future Core Strategy review • Have also checked they do not harm its overall will determine the overall scale of development sustainability there

27 Proposed Focused Changes 2 Timetable for comments • Affordable housing target reduced from 40% • Comments are invited – but only on the focused to 35% changes, not the plan in general • References to the Ipswich Policy Area changed • Please submit them by 5pm on Monday 17th to wider Ipswich area – but commitment to cross January 2011 boundary working remains • Please use the web consultation module if possible • Number of Gypsy and Traveller pitches reduced to submit comments to reflect local need www.ipswich.gov.uk/corestrategyexamination • Minimum housing density removed or write in or email

What happens after this? Latest News: Regional Spatial Strategy Update • 17th January deadline for comments th • Mid February Council hands all duly made comments to • High Court ruling on 10 November reinstated the regional Inspector spatial strategy • Late February Pre-Hearing Meeting or Inspector issues • Letter from CLG received the same day says RSS will be revised list of Matters, Issues and Questions abolished through the Localism Bill due for publication before Christmas and that the letter sent back in May • Early May hearings take place announcing the intention to do that remains a material consideration.

In conclusion • Council decided that it would continue with the Core Strategy • Need a strategy in place to guide development and avoid ‘planning by appeal’ • Northern Fringe numbers will be determined through a future review • Please take the opportunity to comment on the Proposed Focused Changes.

28 Appendix 6 Note of Discussion Group held on 6th January 2011

Ipswich Borough Council Core Strategy and Policies DPD Proposed Focused Changes Public Consultation Development Industry Discussion Group

Venue: Council Chamber, Ipswich Town Hall

Date: 6th January 2011

Attendees (in three different discussion groups) Group 1: Mike Tee Ipswich Borough Council Bob Kindred Ipswich Borough Council Stuart Cock Mersea Homes Martin Blake Merchant Projects Mike Goodson Iceni Homes Samantha Robertson Ipswich Borough Council (scribe)

Group 2: Sarah Barker Ipswich Borough Council Denis Cooper Ipswich Borough Council Martin O’Hara Associated British Ports Nicholle Phillips Crest Nicholson Andrew Hunter Environmental Agency Kevin Coleman JB Planning Associates Ltd Joanne Fox Planning Potential Rebecca Greasley Ipswich Borough Council (scribe)

Group 3: Robert Hobbs Ipswich Borough Council Eric Cooper Highways Agency Christopher Smith Hopkins Homes Annie Ruffell Kesgrave Covenant Andy Redman Savills James Cutting Suffolk County Council Christopher Fish Ipswich Borough Council (scribe)

Note: This paper is not the opinion of the Council but represents the views made by those who attended.

29 Introduction

A discussion group with the development sector was held on Thursday 6th January 2011 between 2pm and 3.30pm in the Council Chamber at Ipswich Town Hall.

Mr Mike Tee, Head of Planning, Transport and Regeneration introduced the session and Mrs Sarah Barker, Principal Planner at Ipswich Borough Council, began with a presentation about the proposed focused changes consultation and where the Council is now in the local development framework process (presentation slides attached).

Attendees were divided into three groups to give a broad representation of different interests to ensure wide-ranging discussion. Following the presentation, each discussion group focused on the same six questions in relation to housing and infrastructure delivery in the Borough, which will also inform an update to the Council’s strategic housing land availability assessment. Below is a summary of the combined key points or areas of disagreement arising out of the discussion groups.

1) The Government talks about stabilising prices. How do you perceive house price movement, particularly in Ipswich, in the short-term? 2) How do you perceive the housing market to look like beyond five years time? Will the market recover to its former state or will it have undergone structural changes?

There was a general consensus that it does not look like there will be a house price increase in 2011. There is not enough supply in the market currently with limited mortgage availability and high deposits required. Any upturn would be linked to the economy and do not assume there will be another boom as the Government does not want this. It is not just jobs that create housing need though.

There is an expectation that the housing market will be subdued over the next five years and there is a need to find ways to maintain housing delivery, however it will take longer than five years to get back to the boom time, or Regional Spatial Strategy (RSS) levels of delivery unless urgent action is taken. It was argued Ipswich needs to release more land for housing and employment and there is a lack of sites in Ipswich that are suitable to build on now. The banks are not interested in high-density and brownfield hence the reason why greenfield must be released now.

A 3% per annum rise in house prices is what developers would hope for, but in Ipswich prices are expected to remain flatter due to the distance from London. Flats at the Waterfront are empty and are therefore being sold off at a reduced price. Unfinished flats at the Waterfront will affect the market in that location. It also makes these schemes unviable, as sales values do not cover cost.

There are two housing markets in Ipswich. One for family houses of two to four bedrooms, which are selling well, and this is a steady market. The other is for the singles and couples flats market, which has gone down in value. There are fewer investors and there are no first time buyers. There is a big demand currently for rental property, because there is very little new stock.

Land values are dropping from around £1 million an acre to around £0.5 million an acre. Brownfield land can have a negative alternative use value for residential use as residential land is currently under market pressure and the abnormal costs often associated with such redevelopment sites can make alternative redevelopment unviable in difficult market conditions. The number of units sold often influences land values and the fall in the number of units being sold on the market has contributed to the drop in land values. However a counter view was expressed that the lack of

30 finance for developers and fewer buyers has led to a fall in the number of units being sold on the market and this has partially contributed to the drop in land values. Ipswich is in a weaker market location compared to London and a small drop in sales value has a big impact on land value.

The cost of construction is also going up with an increase in costs to meet the Code for Sustainable Homes, and building regulations are tightening, these both serving to reduce land value.

There was a feeling that the structure of the housing market is not going to change dramatically. There is a need to build two and three bedroom semi-detached houses for buyers to be able to afford on an 85% mortgage. Institutional investing may occur through housing associations.

Over the next five to ten years there will probably still be no great demand for high cost flats, and while there is no market for high-density living these flats will not be developed. Brownfield sites are likely to be unviable. Student accommodation is also unpredictable and depends on the growth of the college and the university. It is difficult to predict the growth in student numbers, as the university has not yet established a reputation. The student population could soak up some of the open market flats and existing flats on the Waterfront.

3) Have the amendments to Planning Policy Statement 3 on Housing in June 2010, with the removal of the minimum density requirement and the reclassification of garden land to greenfield affected housing delivery in your experience?

The Government has not announced that you cannot develop on garden land. PPS3 just makes it more difficult to get it developed.

Developers are relaxed regarding the changes to density standards, as they also do not have to develop at too low or high a density and can deliver much needed family housing. It does not necessarily move the market towards a more executive market but instead provides a better balance of units, with more outlets and more of a mix. Higher densities were more of a response to the buy-to-let market and former national planning policy guidance.

There is a tenure change as wages are not going to go up significantly and houses are unaffordable so more are being rented. House prices will go up in line with inflation.

Low-density still requires the efficient use of land. It is not the case that every piece of brownfield land has to be built upon, and there are still considerations about the character of the area and open space provision.

4) How do you see infrastructure being funded in the future?

Infrastructure could be funded through a variety of measures such as the New Homes Bonus, Tax Increment Financing (TIF), Community Infrastructure Levy (CIL) money, and developers wanting infrastructure to happen. There will be more partnership working. There is concern that relying on a local authority to put infrastructure in is not the sensible route. The TIF mechanism will mean that all of the money will not be able to be used at once and the County Council want contributions shared. Also regarding these third-party funding opportunities the Waterfront development planned will probably be higher density, but arguably contribute less to any capital funding.

31 With regards to the flood defence barrier, it is an expensive project with £3.4 million of funding from the Haven Gateway Partnership but the majority of funding coming from DEFRA. There is an expectation that the Ipswich barrier will score well in DEFRA’s cost benefit analysis. The barrier’s completion is expected in 2014 and this is the date specified in documentation. Others however speculate that it may be delayed.

Ipswich Borough Council has some costings for strategic items, such as the flood defences, and is still working up more detailed costings for other items of infrastructure. Suffolk County Council is preparing a consultation document on Section 106 contributions needed to fund infrastructure such as schools but viability will always be a consideration.

The Code for Sustainable Homes is adding cost to developments, with Code Level 3 costing an extra £5,000-£6,000 per dwelling, Code Level 4 £11,000 per dwelling and Code Levels 5 and 6 £45,000-£60,000 per dwelling.

There is a need to separate strategic infrastructure from individual development- related infrastructure. The Police and NHS for example need to be funded as a package through the likes of CIL. TIF while theoretically possible will pose a huge risk for local authorities, and they are risk-averse. Tariffs are likely to be seen in the Suffolk area.

5) What are your views on the type of housing products that are currently in demand and is the supply meeting this demand?

There is a mixture of demand dependent upon affordability. The average price for a flat in Ipswich is approximately £120,000. Developers will spread the risk in different sectors, and are currently selling more three and four-bedroom houses because there are no first-time buyers and therefore it is currently very hard to sell starter homes. However another view was that developers were selling more two, three and four bedroom houses because there is demand for it, rather than for apartments.

There is demand from people living alone who do not want one-bedroom units. Demand is not driven by what people want but what they can afford. All needs studies are showing a strong demand for two, three and four-bedroom houses, but buyers are sometimes having difficulty getting finance.

Apartments are being let in the rental market but are not in demand as far as owner- occupation is concerned. If finance is freed up, there is a thought that the apartment market will not grow as it did in the boom times with up to 80% of sales for buy-to-let, as this market is no longer active.

A popular housing type by a volume house builder is a detached house with a garage next to it so occupiers can see their car. House builders do not want central parking courts. Densities can be achieved like at Ravenswood and this works well. People want good space standards and secure neighbourhoods.

6) Flats and apartments often meet the need for first time buyers, those who wish to live at a higher density in town centres, and those who want low cost rent. How and where do you seen flats and apartments being delivered over the next 5 to 10 years? Is it largely high-density schemes that have become stalled during the recession?

Ipswich Waterfront is the only place where high-rise development can work in Ipswich. The Homes and Communities Agency (HCA) high-density report shows a move away from conventional housing layout but it is questionable whether this will

32 bring a change in attitude. Good examples of flats are at Henley Road/Valley Road and Felixstowe Road and at five to six storeys in height. However it was also argued that flats should only be a small percentage of future delivery as a balanced market is required.

In the next five to ten years, lenders are going to be nervous in the apartment market. Developers will not build as many flats, and in Ipswich there is a lot of brownfield land, which will see low levels of delivery due to the land value. Therefore it was argued Ipswich is over reliant on these types of schemes.

If Ipswich needs economic growth, then there is a need to preserve industrial land to provide jobs. Small business and car repair businesses in particular locate to lower cost brownfield sites that are affordable for their business and often move to better premises once it becomes cost effective.

Proposed Focused Changes General comments on the proposed focused changes were raised concerning the proposed supplementary planning document (SPD) for the Northern Fringe and concerns were raised regarding the 700 units target and that the 15-year period start date was incorrect. The Core Strategy needs to advise how many dwellings the Master Plan needs to plan for rather than at a Core Strategy Review and a red line needs to be drawn around the whole Northern Fringe site.

The Council intends to revise the local development scheme (LDS) to bring forward the SPD work on the preparation of the Master Plan for the Northern Fringe, to tie in with the Core Strategy policy CS10, following the appeal decision regarding proposed development in North Ipswich. It was questioned why delivery is still being held back until 2016 for the Northern Fringe.

SHLAA sites Stakeholders present made the following points or comments:

 Contended the SHLAA does not always conform to guidance and was therefore overly optimistic on delivery even though it shows very poor delivery over the next five years.

 Developers identified that the Core Strategy refers to phasing over the six- year period and this differs to the phasing set out on the SHLAA map tabled. They stated that the AMR premise is to show how Ipswich Borough Council is performing and indicates the Council’s housing delivery is under target. Therefore there is a need to release greenfield land to meet this shortfall.

 Some stakeholders considered that the housing trajectory is weak, as it shows a lack of understanding of the build process. The delivery of flats is unlikely to take place in the year-on-year pattern suggested in the SHLAA. Other local planning authorities ask the developers to provide likely build rates on a year on year basis, for example the build rate at Griffin Wharf and Regatta Quay are viewed as unrealistic.

 The Helena Road site (reference IP226) is subject to a Section 106 agreement and this has been the case for six years now. The house builder’s option on the site runs out soon and therefore the scheme is unlikely to happen in the foreseeable future.

33  The extant planning permission list shows 13 schemes that have now expired. These are schemes, which did not come forward in 2006, 2007, 2008 and 2009, so there is no chance they will come forward now. These schemes should be classified as windfall.

 A build rate of 300 units per annum could be achieved on the Northern Fringe. This is a lot to expect the developers to build and sell. Some years it is reasonable to expect a much lower build rate, e.g. 100 per annum but not over a ten-year period. Another view was that a build rate of 300 private dwellings per annum is achievable on the Northern Fringe but on a number of outlets.

 The last five years of the trajectory show 330 units to be delivered on large unidentified brownfield sites. As the SHLAA is very detailed looking at all possible opportunities it is unrealistic to assume such a high number of unidentified units to come forward. To forecast a total of 400 windfall units for the last five years of the trajectory is too high and open to criticism. For the previous five years Ipswich Borough Council have significantly over projected their trajectory, which has held back greenfield releases.

 The Island site is phased to follow the construction of the flood defence barrier, expected to be complete in 2014. The landowner supports its inclusion in years six to ten, although believes delivery will begin at the latter end of that period.

 The Northern Fringe should be brought forward on the basis of uncertainty around the delivery of sites dependent on the flood defence barrier.

 Shed 8 is currently being used as a car park. Prospective developers keep applying for planning permission to try to add value to the site.

 The long-term site for Ipswich Borough Council is the Northern Fringe. Some people have had issues with the development of the Northern Fringe, as it is popular with ramblers. However in recent months public interest groups regarding the Northern Fringe have gone on record to say if there is to be development there, then it must be planned for comprehensively.

 The phasing of the Northern Fringe was questioned and why all of it cannot be built together? One planning agent argues that Ipswich School’s land north of Valley Road is different from other land being promoted in the Northern Fringe, because as well as providing new housing, its redevelopment could facilitate, by providing the funding for, the development of a sports park on the School’s land west of Tuddenham Road, also in the Northern Fringe, for which there is a significant current need. The School’s land north of Valley Road would form a logical extension to the existing northern boundary of Ipswich it was stated.

 Issues have been raised regarding the odour on the sewage works site in relation to sites IP058, IP067 and IP072. There is not a ventilation system yet that can completely eliminate the sewage odour but improvements have been carried out in recent years and more are expected. It is an issue that has been raised by Anglian Water. Deliverability of those sites next to the sewage works was questioned.

34  There are potential issues with the former British Energy site (reference IP067) – part of the site is unavailable and therefore the boundary needs amending, and topography should be considered.

 In respect of the site at Great Whip Street (reference IP038), unless HCA funding is guaranteed, the proposed development cannot be included in the first five years. In time the site could and may be developed but at present the landowner would look to let the warehouse on the site for five years.

 The capacity of the trajectory is ok but the phasing is wrong. The brownfield average over the first few years is 82.5% and with weak viability the affordable housing that would be delivered would be less than 20%. Ideally the maximum delivery at the Northern Fringe would be 150-200 dwellings per annum to not flood the market. The market will dictate what gets built and when but it is important to have schemes that are viable and available to developers Therefore there would be more homes being built now in the Northern Fringe. Another view was that the ideal delivery at the Northern Fringe would be 300 private dwellings per annum.

General discussion included the latest position on the tidal barrier. Ipswich Borough Council confirmed that the DEFRA/Environment Agency funding was still expected to be forthcoming. Developers questioned whether the funding will be made available as the total DEFRA capital investment pot has been reduced and suggested that some third-party contributions would be needed to deliver it.

The Ipswich: Fit for the 21st Century transport scheme is a county scheme and confirmation is expected in January as to when the county will receive the money.

Questioned why the Northern Fringe bypass and the Wet Dock crossing had been taken out of the Core Strategy, Ipswich Borough Council advised that whilst these schemes remain aspirations they may not be delivered in the timeframe of the plan because of cost and Suffolk County Council highways does not consider that they are essential. In response to this a comment was made that without the Wet Dock crossing, the Island site is not deliverable and should be taken out of the SHLAA. However a counter view was explained that the Island site is not dependent upon a Wet Dock Crossing. Furthermore, there is a view that the Wet Dock Crossing would have potential adverse impacts on marine traffic through the lock and rail traffic into the West Bank Terminal and its deliverability is therefore questioned.

Additional comments on the SHLAA were reported stating that not enough allowance had been given for loss of units due to demolitions. The Council explained that demolitions are counted in the year they occur as a loss.

Planning permission for 31 units on the site at Cambridge Drive granted in 2007 has lapsed, so should be removed. The Council note this site has been completed in the 2010-11 monitoring period and therefore is included in the housing trajectory.

The site at Stoke Park Drive (reference IP168) should have 20 units deleted. There is a query over the net units, as it has not currently recorded the demolitions. The Council note the demolitions have been recorded in a previous monitoring period as a loss of 20. Therefore the net gain is 11, but as 20 dwellings have already been taken out of the housing stock, 31 will be added in the next five years.

Developers stated that there was not enough time to discuss each individual site and referred Ipswich Borough Council to representations made for the Core Strategy.

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