Agenda item

E/19/34 Final Draft Ipswich Local Plan - Regulation 19

Portfolio Holder – Councillor Carole Jones


This report explains the changes arising from the Preferred Options draft Local Plan reported to Executive in November 2018. These proposed changes result from responses to representations received from the consultation of the Preferred Options draft Local Plan (Regulations 18) (held earlier this year) as well as additional changes made to reflect changes to Government policy, including updates to the National Planning Policy Framework and the Planning Practice Guidance.


This has resulted in the Final Draft Ipswich Local Plan for publication under Regulation 19. 


If supported by Executive this draft Plan will be considered at the next Full Council meeting – and if then agreed – would be the subject of public consultation.


This report seeks authorisation to publish the Final Draft Ipswich Local Plan (Regulation 19 version) for public consultation and then for it to be formally submitted it to the Planning Inspectorate for Examination.  These formal stages of plan making are covered by the Town and Country Planning (Local Planning) (England) Regulations 2012 as amended in 2017and 2018.  Public consultation will be carried out in accordance with the Ipswich Statement of Community Involvement Review March 2018.  It is proposed that the public consultation would start on 22 November 2019 and conclude on 20 January 2019 (thereby running for 8 weeks).


71.1      Councillor Jones introduced the report, highlighting the importance of the Local Plan to the future development of Ipswich. Councillor Jones noted that an addendum had been circulated which included updates to the Council’s development management policies which had been made after an informal meeting of interested Councillors.


71.2      Councillor Jones reported that new version of the Local Plan had been influenced both by changes to the National Planning Policy Framework and by local studies, assessments and information. Councillor Jones also noted that some sites which had previously been allocated for housing had been removed from this list owing to a change in the definition of deliverability.


71.3      Councillor Jones noted that, if the recommendations of the report were agreed by Executive, the draft Local Plan would be considered by Council, and then submitted to a public consultation and consideration by a planning inspector.


71.4      In accordance with Standing Orders Part 3 Section 3 Paragraph 3.5, the following questions were asked:


Question 1 – Councillor Holmes

Given that 55% of traffic in Ipswich comes into the town from neighbouring authorities, causing significant congestion and pollution for local residents, is the Portfolio Holder confident that the aligned local plans will address problems caused by development of housing in these authorities close to the Ipswich Borough boundary?


71.5      Councillor Jones explained that whilst better aligned local plans would help with reducing traffic and pollution, the key factor was the decisions made on planning applications and the conditions and obligations attached to these. Councillor Jones noted that decisions were guided by Suffolk County Council’s Transport Mitigation Strategy which applied to Ipswich Strategic Planning Area authorities. Councillor Jones explained that the Council had a number of strategies to reduce congestion and improve air quality but that Central Government needed to take a proactive approach to make a real difference.


Question 2 – Councillor Holmes

As the actual delivery of completed housing in the first years of the current plan is substantially below the housing need of 445 units per annum, are not the figures for projected completions in the plan period hopelessly optimistic?


71.6      Councillor Jones commented that the figures in the plan were not, as Councillor Holmes had suggested, hopelessly optimistic. Councillor Jones noted that the figures were the minimum arising from the Government’s methodology that Ipswich must provide, and explained that the plan sought to deliver that requirement in an appropriate way. Councillor Jones reported that the plan used a phased delivery target in order to reflect the projected completions through the plan period, including those from the Ipswich Garden Suburb. Councillor Jones confirmed that legal advice had been taken on the Council’s approach and it had been confirmed that the housing numbers were realistically deliverable. Councillor Jones noted however that the Council was dependent on private developers to implement permissions granted to ensure that Ipswich’s housing needs were met.


Question 3 – Councillor Holmes

Similarly, given the low level of affordable housing in planning permissions granted, with levels of less than 5% in the Ipswich Garden Suburb due to viability restraints, is there any evidence that affordable housing in new developments will achieve the levels given in the Final Draft?


71.7      Councillor Jones explained that draft Local Plan affordable housing target had been set after having considered a Whole Plan Viability Assessment undertaken by consultants which demonstrated that 15% affordable housing was achievable in Ipswich, particularly on housing-led schemes rather than flat-led schemes. Councillor Jones agreed to send Councillor Holmes further information regarding this.


Question 4 – Councillor Holmes

As there is no evidence of modal shift for transport in Ipswich leading to reduced congestion and pollution in the town centre, should not the Ipswich parking strategy aim to reduce long term commuter parking at least outside operational parking in new development?


71.8      Councillor Jones explained that the Ipswich Parking Strategy assumed a 10% reduction in the estimated level of car parking demand as a result of the successful implementation of sustainable transport measures. Councillor Jones noted that the Ipswich Parking Strategy contained a number of different options for how to determine what the level of demand for public car parking would be in the wider town centre area by 2036 but commented that it was difficult to assess this as changes to Government policy could lead to significant modal shift.


71.9      Councillor Jones explained that it was important to strike the right balance between the need to ensure that there was sufficient public car parking to assist the economic wellbeing of the town centre with the need to ensure that traffic congestion and air pollution is avoided by not over providing car parking. Councillor Jones noted that the total net change in the number of parking spaces over the plan period was an increase of just 3 spaces, but that the strategy should result in higher quality car parking spaces in the areas of the town centre where it was needed. 


71.10   Councillor Fisher asked whether any traffic modelling had been completed on the impact of the Ipswich Parking Strategy. The Operations Manager for Planning and Development confirmed that a number of transport modelling scenarios had been considered and that the Suffolk County Council Transport Mitigation Strategy would promote improvements in air quality and congestion. The Planning Policy Team Leader explained that potential housing sites which fell within Air Quality Management Areas had been excluded from the site allocations whilst a Low Emissions Supplementary Planning Document was also under development.


71.11   Councillor Fisher asked for information on the Opportunity Sites identified in the Local Plan. Councillor Jones explained that the sites were not included in the figures for the 5-year housing supply. The Planning Policy Team Leader explained that the Opportunity Sites had been listed as they were considered to be appropriate locations for housing but that there was no certainty about when they would come forward for development and so could not be included in the housing allocation.


71.12   Councillor Ellesmere queried when the Local Plan could be taken to Council if a General Election was called. The Chief Executive noted that if a General Election was to be held in the week commencing 9 December the next ordinary meeting of Council was likely to be cancelled and that an additional meeting might need to be scheduled early in 2020.




that that the matter be referred to Full Council with recommendations to:


a)     Authorise the Head of Development to undertake formal public consultation under Regulation 19 on the Final Draft Ipswich Local Plan and supporting documents attached at Appendices 1 to 8 and as amended by the addendum, in accordance with the Regulations and the requirements of the Statement of Community Involvement dated March 2018. 


Reason: The two development plan documents set out in the appendices will ensure the Council is planning positively to meet needs and is progressing towards a Local Plan which is aligned with the plans of its neighbouring authorities.  Formal Public consultation is required on the final draft plan prior to submission to the Secretary of State.


b)     Up to the start of the consultation period, referred to in 13.1.1 above the Head of Development, in consultation with the Portfolio Holder for Planning and Museums, be authorised to:


i)       accept and amend the consultation documents referred to in this report as they consider necessary following receipt and consideration of the sustainability appraisal report; and/or


ii)     amend the wording or layout of the consultation documents referred to in this report provided that in relation to (b) any changes are minor in nature.


Reason: Up until the start of the consultation period it may be that officers will identify areas where the consultation documents could be improved in wording and layout terms without impacting on meaning, or make amendments following receipt of the sustainability appraisal report. This recommendation will provide the Head of Development the ability to undertake any minor such changes.


c)    Authorise the Head of Development, following consultation with the Chief Executive and the Head of Governance, to sign the updated Statement of Common Ground (Appendix 7) on behalf of Ipswich Borough Council.


Reason:  The Statement of Common Ground will evidence the joint working with neighbouring authorities through the Duty to Co-operate and will need to be signed at the appropriate time for each of the Local Plan Reviews relating to authorities within the ISPA area.


d)   Authorise the Head of Development, following consultation with the Chief Executive, the Head of Governance, the Leader and Portfolio Holder for Planning and Museums, to submit the Draft Ipswich Local Plan to the Secretary of State for examination following the Regulation 19 consultation.


Reason: The Regulation 19 consultation stage of the draft local plan is the formal interaction with the public on a plan that the Council considers to be sound for the purposes of meeting identified need for the plan period. The role of officers at this stage is as a conduit between the public and the appointed Inspector. The Regulation 19 final draft Local Plan that goes out to consultation is the Council’s final draft and therefore, ordinarily, it is not expected to make any further amendments prior to submission of the plan to PINS. The local plan would not ordinarily be amended after consultation so should be sent to PINS without further change or authorisation.


e)   Authorise the Head of Development, in consultation with the Portfolio Holder for Planning and Museums, to discuss and agree to modifications necessary through the examination process.


Reason: to ensure the smooth running of the Inquiry and immediate post Inquiry process. Without such approval, the examination process cannot function.

Supporting documents: