item 4 application no. ip/16/01220/out 4.pdf · item 4 application no. ip/16/01220/out ward:...

PLANNING AND DEVELOPMENT CONTROL COMMITTEE 20th SEPTEMBER 2017 REF. NO. PD/17/07

(Reps)

Item 4 Application No. IP/16/01220/OUT

Ward: GIPPING

Proposal: Outline planning application for up to 128 dwellings (C3) and 60 bedroom carehome (C2) with details of access from Hadleigh Road (Scale, appearance,landscaping and layout as reserved matters) following demolition of existing on sitebuildings/structures. Submission includes indicative internal roads, footpaths,landscaping, open space, drainage measured, levels and associated infrastructure.(Development site within Ipswich Borough Council and Babergh District Council).

Address: Former Site Of Elton Park Works And Arclion House, Hadleigh Road

Applicant: M & D Developments

Agent: Mrs Jo Hanslip


Recommendation

Grant planning permission for the cross boundary development subject to:-

A) The completion of a legal agreement under provisions of section 106 of the Town

and Country Planning Act (1990) dealing with the following matters:

i) NHS - £55,200

ii) Education - Primary /Secondary - £500,256

iii) Pre School - £60,910

iv) Libraries - £1,648

v) Highways – Land Transfer (-£1); Pedestrian Crossing - £80,000; TRO - £10,000

vi) Bus Infrastructure - £7,500

vii) Travel Plan – Monitoring - £5,000; and Travel Plan Bond £91,721

viii) IBC Open Space Provision - £137,768; and maintenance £10,184

viii) IBC - Habitats Regulations Assessment - £21,524

ix) Public right of way through the site bridge landing point to Hadleigh Road

x) Viability review prior to completion of phase 3 and 5 of the development.

xi) Community Infrastructure Levy charging schedule for BDC (as applicable).

B) Grant planning permission upon condition that (briefly):-

1. Reserved Matters to be submitted within 3 years, and development to be commenced

within 3 years of approval of the final reserved matter.

2. Development to be in accordance with the approved phasing plan, and access plans.

3. Restriction that no commencement of development of a phase until details of that phase

have been submitted as a reserved matters application and approved.

4. Details to be submitted with each reserved matters application prior to commencement

of each phase of development: Layout; Numbers and mix of residential units;

Design/Scale/Appearance of dwellings; Landscaping details; site levels; Foul and

Surface water drainage strategy and phase design details.

5. Details of fire hydrants to be approved.

6. Finished ground floor levels to be set no lower than 7.15 metres above Ordnance Datum

(AOD).

7. Emergency access / egress plan to be agreed and circulated to occupants. Emergency

plan to be maintained permanently.


8. Submission and agreement of risk assessment covering contamination of the

watercourse. Phase by phase approach.

9. Verification report covering completion of contamination works.

10. Long-term monitoring and maintenance plan in respect to contamination.

11. Notification of any contamination not previously identified to the LPA. Works to stop until

a remediation strategy has been agreed. Remediation to be fully implemented.

12. Before the development is commenced, details of the proposed access junction onto

Hadleigh Road shall be submitted to and approved in writing by the Local Planning

Authority. The approved layout shall be provided prior to any other works commencing.

13. Prior to first use of the highway junction visibility splays to be provided, and thereafter

protected.

14. Details of the proposed estate roads, footways, cycle routes and emergency access

(including layout, levels, gradients, lighting, traffic calming, signage, surfacing, private

vehicular accesses off the new estate roads and means of surface water drainage) to be

provided and approved.

15. Photographic condition survey of the highways fronting and near to the site has been

submitted to and approved.

16. Existing accesses to be permanently ‘stopped up’ in a manner to be agreed in advance

by the LPA.

17. Ecological Survey recommendations to be fully implemented.

18. Landscape and Ecology Management Plan for the northern river fringe to be submitted

and approved by the LPA. Agreed plan to be implemented.

19. Archaeological watching brief. Before and deep excavation is commenced on site in

association with site leveling or SUDs/Foul drainage systems SCC Archaeological Unit

to be informed to allow site observation, and recording.

20. Dwellings to meet energy and water usage standards. Details to be submitted and

agreed and then implemented as approved. (IBC)

21. Development to provide 15% of energy from renewable or low carbon sources. Details

to be provided, agreed and implemented. (IBC – 10% within BDC).

22. Dwellings to be provided with high-speed broadband connection points.

Informatives:-

1. Environment Agency informatives.

2. Suffolk Constabulary comments regarding secured by design principles for detailed layout

stage.


The application is a cross boundary planning application where a smaller element ofthe overall site falls within Babergh District Council’s administrative control.

Babergh District Council have, in relation to this particular application, devolved theirdevelopment management powers to Ipswich Borough Council.

The application therefore can be determined in full by Ipswich Borough Council.

This application is an outline application with all matters reserved except access. Thereserved matters are Appearance, Landscaping, Layout, and Scale.

The applicant is M & D Developments Ltd.

1. Proposal

The proposals are an outline application, considering the principle of the describeddevelopment, with the means of access only being considered as part of the details assubmitted by the applicant at this stage. Therefore a further ‘Reserved Matters’ applicationwill be required to examine the full details of layout, scale, appearance and landscaping,should this application be approved.

The site is a former industrial site located to the north of Hadleigh Road, to the west of theIpswich Railway Chord and Elton Park employment area. The site has a boundary with theriver Gipping to the north and includes the former Arclion House site, with a portion of thesite to the west within the Babergh District Council administrative area. The site isapproximately 4.3 hectares in area, where the majority of the developable land is withinIpswich (3ha) and a smaller amount within Babergh (1.3ha).

Outline permission is sought for development comprising up to 128 dwellings includingprovision of a 60-bedroom care home. The site would have access from Hadleigh Road.Plans have been submitted showing an indicative layout of the development through the sitewith a quantum of development which is broken down as follows:-

Ipswich Borough – up to 103 dwellings.

Babergh District – up to 25 dwellings, and a 60-bed care home.

The application is supported by:-

Planning Statement

Design and Access Statement;

Indicative masterplan

Indicative streetscene drawings

Air Quality Report

Arboricultural Impact Assessment (AIA)

Transport Assessment / Draft Travel Plan

Drainage Statement

Energy and Water Statement

Noise Assessment – Care Home

Phase 1 Geo-Environmental Study

Statement of Community Involvement

Protected Species / Ecology Survey


Refuse Strategy Plan

Viability Statement (Confidential – commercially sensitive information)

2. Background

The application site is comprised of the former Manganese Bronze factory works which

became vacant in 2008.

Since 2008 there have been a number of planning applications for the redevelopment of the

land in both in Ipswich and Babergh. In 2008 there was a resolution to grant outline planning

permission for redevelopment of the site for 130 dwellings and 7,260 of B1 office space, and

a 70-bed care home, all with access from Hadleigh Road (IP/08/00365/OUT refers). The

application was eventually withdrawn with the s.106 agreement not having been signed.

Prior to this in 2007 an application was withdrawn for residential development of up to 180

flats/houses, 80 bed care home in 2-4 storey blocks, light industrial units (Class B1) and

replacement general industrial (Class B2) for the original occupant Oilite Bearing Ltd

(IP/07/00381/OUT refers).

More recently in 2010 permission was granted for Arclion House directly at the southern end

of the current site, adjacent to Hadleigh Road for 18 affordable units (IP/10/00823/FUL

refers), then a more recent revision for the Arclion House site for 12 dwellings having a

resolution to grant planning permission subject to a s.106 agreement (IP/16/00576/OUT

refers).

In Babergh permission has been granted on the Geest House site (also fronting Hadleigh

Road) for change of use from office B1 to residential (B/13/0140/GDPO refers) and for the

erection of 8 dwellings too the rear (B/14/00460 refers). The Geest site does not make up

part of the current outline application and sits outside of the red line.

The applicant has undertaken an informal consultation event of 06.10.16 where residents

and key stakeholders were invited to a presentation detailing the outline application.

3. Procedural matters

In circumstances where an application site crosses the administrative boundary between two

Local Planning Authorities (LPAs) the National Planning Practice Guidance (NPPG) dictates

that under these circumstances two identical applications must be submitted to each LPA,

identifying on the plans which part of the sites is relevant to each. The planning fee is paid to

the LPA whose area contains the largest part of the application site.

In this case the significant majority of the application site falls within the administrative area

of Ipswich Borough Council, accordingly the application fee has been paid solely to Ipswich

Borough Council.

In the absence of alternative administrative or statutory arrangements, a planning application

should be determined by the LPA in whose administrative area the development is proposed

to be carried out. In the case of cross-boundary applications, this can lead to two LPAs

making individual determinations, imposing different planning conditions, on the permissions

and entering into separate s106 agreements. This is not recommended as it does not

promote a coordinated approach to development management and the permissions granted


by each LPA may be inconsistent. It is also contrary to Government guidance, which

encourages joint working between LPAs in relation to their planning powers. Paragraph 178

of the National Planning Policy Framework (NPPF) advises that public bodies have a duty to

cooperate on planning issues that cross administrative boundaries, particularly those which

relate to strategic priorities. The Government expects joint working on areas of common

interest to be diligently undertaken for the mutual benefit of neighbouring authorities, a

concept which underpins the approach to strategic plan-making.

Pursuant to section 101(1) of the local Government Act 1972 a local authority may arrange

for the discharge of any of its functions by a Committee, a Sub-Committee, an officer of the

authority or by any other local authority.

Accordingly Babergh District Council has delegated its decision making powers to Ipswich

Borough Council in respect of the determination of this particular cross-boundary planning

application. In respect of which Ipswich Borough Council would then determine both the

applications and agree the terms of any necessary planning obligation under section 106 of

the 1990 Act, subject to Babergh District Council’s final approval or the relevant sections.

Babergh District Council agreed to devolve its planning powers at its full Council meeting on

7th August 2017 (ref BC/17/11).

Babergh District Council would still be the enforcing authority for any planning obligation

relating to that part of the development in their Council’s area, and any future general

planning enforcement, as would Ipswich Borough Council on development within Ipswich.

Any associated obligations in the form of a legal agreement would need to be entered into by

the relevant land owners and both Council’s.

Babergh District Council Planning Committee has been asked to agree comments to be sent

to Ipswich Borough Council to assist them in determining the application. The Babergh

District Council report to their Planning Committee, held on 30th August 2017 is attached as

Appendix 1. Any further applications relative to this specific site, including any reserved

matters applications, would be the subject of a the normal decision making process unless

the two Councils agree otherwise similar arrangements.

Accordingly Ipswich Borough Council is now in a position to determine the entire application,

and negotiate any relevant planning obligations having regards to the Ipswich Core Strategy

and Policies DPD review (2017) and the Babergh Local Plan (2014).

4. Consultations

Babergh District Council (as Consultee) – No objection to the application, subject to the

agreement of a Section 106 (IBC) and CIL contributions (BDC).

Notwithstanding the five year housing position of Babergh District Council, any new housing

needs to be properly integrated with the wider area and future development of the Sugar

Beet Site to ensure appropriate infrastructure provision is maximised.

IBC Urban Design – No objection. Approval as a basis for detailed design but the schemeneeds to make much more of its location between Hadleigh Road and the riverside.

Reposition public open space from the Hadleigh Road frontage to within the site, along thecentral avenue, where it can contribute to place making for residents and footway / cycle


users. Garden spaces can front Hadleigh Road. Reinforce the central avenue with treeplanting – this should not be diluted at the detailed stage, but rather enhanced with moremeaningful opens spaces along its length and sufficient quality specimen tree planting.

The southernmost junction with the loop road should be developed as a public space,possibly with POS repositioned from the main road frontage: create a more meaningfulgrouping of buildings, space and tree planting. The homezone is another opportunity forpublic realm development; consider creating a west-east axis to the care home, intersectingthe north-south route of the tree lined avenue.

The northern loop road intersection and the link to the riverside should be formalised as agroup and properly emphasised with building types, placing and good (ie generous)sightlines between space and riverside. There is an attempt at a grouping at present, but itachieves a weak transition across a vehicle turning head, and appears unrelated to eitheradjoining housing or the riverside.

Omit housing on the west side of the site which is cramped and could release some spacefor enhancement of the central avenue area. The general housing design spec isstandardised and varies only in scale across the site. Although a traditional design approachcould be accepted in this location, much more variation of scale, form and detail could beachieved if the building types are properly related to the hierarchy of spaces – treating thecentral avenue and its key spaces as the development focus. The POS enhancementsdescribed above should all be reinforced by housing types which address the spaces fully,make the most of sightlines and landmark locations and express a comprehensiblehierarchy. A mix of modern and traditional could also be considered, for instance using amodern approach along the avenue and the riverside (see Ravenswood as an example).

IBC Environmental Health - A phase 1 contaminated land assessment is included this

recommends further work including a review of all the work so far undertaken and the

likelihood of further investigations. This work is required and until the phase 2 report is

received it is not possible to comment further.

IBC Environmental Health – Private Sector Housing - If any of the dwellings are to be usedas Houses in Multiple Occupation, they should meet this departments fire and amenitystandards. Provided the development meets current building control standards, we have noadditional comments.

SCC Highways - No objection, subject to the application of planning conditions and the

entering into a S106 legal agreement securing:-

The reservation of land (to be agreed by the County Council) on the site necessary to

construct and land the pedestrian and cycle bridge;

Transfer of the land to the County Council for £1 to allow for the delivery of the

bridge, following service of a notice by Suffolk County Council requiring the land to

be transferred. Such notice not to be exercised unless or until permission for

development of the former Sugar Factory has been implemented with no requirement

to provide such a bridge.

Before first occupation, a pedestrian crossing and traffic speed reduction measures

as necessary, shall be provided on Hadleigh Road to the west of the site or not less

than six months prior to first occupation a sum of £80,000 shall be paid to Suffolk

County Council towards the cost of implementing these measures. (The advance is

necessary for the County Council to provide the facility close to first occupation).


Following approval from the County Council and before first occupation, a scheme of

cycle improvements shall be implemented along Hadleigh Road near to the site.

Before any development commences a contribution of £10,000 shall be paid to the

County Council towards Traffic Regulation Orders near the site and including a

20mph Zone Order on the site.

Before first occupation, the kerbs at three local bus stops shall be improved with easy

access kerbs to the satisfaction of the County Council. Alternatively, a contribution of

£7,500 shall be paid to the County Council as local highway authority towards the

provision of easy access kerbs at local bus stops.

A Travel Plan Evaluation and Support Contribution of £1,000 per annum from

occupation of the 100th dwelling shall be paid to the County Council for a minimum of

five years, or one year after occupation of the final dwelling, whichever is longer.

Before any development commences a Travel Plan Implementation Bond, or Cash

Deposit of £91,721 (£717 per dwelling – based on the estimated cost calculated by

Suffolk County Council of fully implementing the travel plan) shall be paid to the

County Council.

SCC Flood and Water Management – Further drainage details required. Updated comments

to be prepared for the Meeting.

SCC Archaeology – The application has been submitted with a desk-based assessmentwhich concludes that the previous land use and landscaping has most likely removedarchaeological remains. It is likely that we would concur with that assessment based on theinformation available, however, the site is very close to Devil’s Wood Pit where significantPalaeolithic remains were recorded from gravel terraces and there would be some residualconcern with deeper works associated with the application.

SCC Infrastructure - The outline application in Ipswich which is split between IpswichBorough and Babergh District. CIL charges are in effect in Babergh, whilst S106 is theonly developer contribution mechanism in Ipswich.

Contributions sought:-

Primary School age range 5-11yrs 26 pupils required @ £12,181 per place. Total £316,706

High School age range 11-16yrs 10 pupils required @ £18,355 per place. Total £183,550

Sixth Form age range 16+yrs 0 pupils required.

Pre-school age range 2-4yrs 10 places required @ £6,091 per place. Total £60,910

Libraries 2.8 items per dwelling @ £5.66 per item. Total £1,648

Suffolk Fire and Rescue Service – Recommends that fire hydrants to be installed within the

development on a suitable route for laying hose. The number of fire hydrants required will be

determined at the water planning stage when site plans have been submitted by the water

companies. Access to buildings for fire-fighting must meet with the requirements specified in

the Building Regulations (Approved Document B). Suffolk Fire and Rescue also requires a


minimum carrying capacity for hard standing pumping/high reach appliances of 15/26

tonnes.

Suffolk Constabulary – No objection. Recommendations regarding deterring criminal activity

within the resultant development are made which should be included within the detailed

planning stage.

Environment Agency – No objection to the development subject to the conditions in relation

to flood risk and contaminated land.

NHS England – No objection. Subject to a developer contribution of £55,200 to mitigate the

impacts of the proposal.

The proposed development is likely to impact on the services of 5 main GP practices and a

branch surgery operating within the vicinity of the application site. The GP practices do not

have capacity for the additional growth resulting from the development.

Suffolk Wildlife Trust – Recommend that the conclusion recommendations within the

submitted ecology report are implemented in full, via planning condition, and that a long term

management plan is secured for the area of the site adjacent to the River Gipping.

Representations

Helen Kembery, 33 Dallinghoo Road, Wickham Market, received 06.02.17

Mr & Mrs Bridges, no address given, received 01.02.17

Mr & Mrs Vidal, The Limes, Elton Park received 23.01.17

Mr Simon Rooke, Saltbox House, Elton Park received 24.01.17

Issues raised:-

1) Increase in traffic and congestion.

2) Impact on doctors and schools from number of dwellings.

3) Lack of parking.

4) Issues regarding boundary location (The Limes, Elton Park)

5) Scale of care home and overlooking.

Babergh District Council – Consultation responses and representations as per report at

Appendix 1.

5. Policy

National Planning Policy

National Planning Policy Framework (2012)

National Planning Practice Guidance (2014)


Local Planning Policy

Core Strategy and Policies DPD (2017)

Policies CS2 (The Location and Nature of Development); Policy CS4 (Protecting ourAssets); Policy CS5 (Improving Accessibility); Policy CS7 (The Amount of New HousingRequired); Policy CS12 (Affordable Housing); Policy CS17 (Delivering Infrastructure); DM1(Sustainable Design and Construction); DM2 (Decentralised Renewable or Low CarbonEnergy); DM4 (Development and Flood Risk); DM5 (Design and Character); DM10(Protection of Trees and Hedgerows) DM17 (Transport and Access in New Developments),DM18 (Car and Cycle Parking), DM26 (Protection of Amenity); Policy DM29 (Provision ofNew Open Spaces, Sport and Recreation Facilities); DM31 (The Natural Environment);Policy DM33 (Green Corridors).

Site Allocations and Policies (Incorporating IP-One Area Action Plan) DPD (2017)

Policies SP1 (The protection of allocated sites); SP2 (Land allocated for housing); SP3

(Land with planning permission or awaiting a Section 106); SP9 (Safeguarding land for

transport infrastructure); SP15 (Improving pedestrian and cycle routes)

Other Ipswich Borough Council planning guidance

Cycling Strategy SPD (2016)

Space and Design Guidelines SPD (2015)

Public Open Space SPD (2017)

Babergh District Council

Local plan details as per report PL/17/13 - Appendix 1

Relevant Core Strategy and Policies (2014); and Saved policies of the 2006 Local Plan.

CS2 (Settlement Pattern Policy); CS12 (Sustainable Design and Construction); CS13

(Renewable/Low Carbon Energy); CS14 (Green Infrastructure); CS19 (Affordable Housing);

CS21 (Infrastructure Provision); EM02 (General Employment Areas); CN03 (Open Space

within Developments); CN04 (Design and Crime Prevention); RE14 (Stour and Orwell

Estuaries); TP05 (New Cycle Link – Sproughton); TP16 (Green travel Plans); HS01(Housing

Development).

6. Comment

Principle of development

The application site is as described above and relates to a former employment site of the

Oilite Bearing Ltd company, which left the site some while ago leaving the site vacant with

many of the building now demolished or in a state of dereliction.

The local planning authority (Ipswich Borough Council) is not currently able to demonstrate

that it has an adequate five year supply of land for housing. Moreover, Babergh District

Council has stated in their ‘Interim 5 year housing land supply statement’ (April 2017) that

they can only demonstrate a 3 years supply of appropriate housing sites to meet the

identified need. Therefore, all Local Planning policies relating to the supply of housing must


be considered out of date and housing applications assessed in terms of the presumption in

favour of sustainable development set out in the National Planning Policy Framework. This

means that development proposals should be approved unless any adverse effects of the

development significantly and demonstrably outweigh the benefits.

The National Planning Policy Framework (NPPF) states that housing applications should be

considered in the context of the presumption in favour of sustainable development, and

development proposals that accord with the development plan should be approved without

delay, unless material considerations state otherwise.

Policy CS7 requires housing land be allocated for continual housing delivery during the plan

period with the aim being of meeting the high housing need of Ipswich. The site is allocated

within the Ipswich Site Allocations and Policies (Incorporating IP-One Area Action Plan) DPD

(2017) for residential development at a density of 45 dwellings per hectare (dph), which

would equate to 105 units across the Ipswich part of the site. This is as per the proposals

under consideration and therefore is appropriate having regards to the relevant allocations

policies SP1 and SP2 to secure housing on appropriate sites within the Borough.

The front portion of the application site in Ipswich is subject to an undetermined application

for outline planning permission for 12 dwellings (awaiting signing of the s.106 agreement)

however this portion will be incorporated into the current outline application site should

outline planning permission be granted. The incorporation of this site would therefore be in

accordance with policy SP3 which seeks to protect sites with extant residential permissions

for housing delivery.

The site is in a highly sustainable location and will result in the use of brownfield land that

has remained vacant for approximately 10 years.

Having regards to the development on the Babergh District Council portion of the

development to the west (amounting to 25 dwelling and a 60-bed care home), Policy EM24

of Babergh’s Local Plan states that: Planning applications to redevelop or use existing or

vacant employment land, sites and premises for non-employment purposes, will only be

permitted if the applicant can demonstrate that their retention for an appropriate employment

use has been fully explored. This may be undertaken in one of the two following ways: 1. by

an agreed and sustained marketing campaign, undertaken at a realistic asking price; or 2.

where agreed in advance, the applicant can demonstrate that the land, site or premises are

inherently unsuitable or not viable for all forms of employment related use.

Whilst it is noted that no evidence of a marketing scheme has been provided, the site does

lie on the Ipswich fringe, and would be accord with the BDC policy CS2 for Ipswich fringe

development. Whilst the development would not be employment generating in the normal

sense (B1, B2, B8) there there are many alternative employment sites nearby (Elton Park

Works, Ipswich Chord site, and Hadleigh Road Industrial Estate within Ipswich, and the

Sugar Beet Factory site within Babergh). The application site already has established

residential dwellings to the west in Elton Park a residential street within Babergh, to the

south and south-east. Furthermore the Babergh portion of the site would be landlocked by

the policy compliant proposals on the Ipswich side of the site, therefore any use of the site,

other than for residential would potentially impact the amenity of the existing and future

residents.


The proposed 60-bed care home whilst not standard employment generating would have an

element of employment associated within, dependent on the level of care provided.

Having regards to the Ipswich residential allocation it is considered that alternative uses of

the BDC element of this site would be undesirable for all but C2/C3 (residential) use.

Therefore whilst not compliant with the Babergh DC employment policy the development

proposals would be a sustainable form of development which is supported by Babergh

District Council (see Appendix 1).

The proposals would therefore help to meet the identified need for housing within Ipswich

and Babergh in accordance with policies CS7 (IBC) and HS01, CS2 (BDC).

Access and highway safety

The allocated site is located on the north side of Hadleigh Road, adjacent to the River

Gipping to its north, with the “The former ‘British Sugar’ (sugar beet factory) site directly to

the north of the river. The site sits on the westernmost periphery of Ipswich where it meets

the Babergh administrative boundary. To the west, within Babergh, on the northern side of

Hadleigh Road are a number of residential roads (Elton Park, Stella Maris, Collinson’s etc.)

which have vehicular accesses onto Hadleigh Road. To the south-west of the site is Chantry

Park in Ipswich. To the east are a number of different employment areas as described

above; however along Hadleigh Road are residential properties in a typical ribbon

development style which is common on arterial routes into Ipswich.

Policy CS5 states that development should be located and designed to minimise the need to

travel, and to enable access safely and conveniently on foot, by bicycle and by public

transport (bus and rail). This will encourage greater use of these modes. The Council will

support the implementation of the Travel Ipswich scheme and will work with the Highway

Authority to manage travel demand in Ipswich and in doing so will prioritise the introduction

of an integrated cycle network. The cycling strategy SPD requires provision for cyclists within

all new developments to be integral to the design. Policy SP9 seeks the safeguarding of land

within the site for a pedestrian and cycle bridge over the river to link to the northern bank.

Policy DM17 seeks to promote sustainable growth in Ipswich and reduce the impact of traffic

congestion. New development is required to not result in sever adverse impacts on rights of

way or the local road network, not result in a significant impact on air quality; incorporate

electric charging and car club schemes where possible; promote pedestrian and cycle

accessibility; provide high quality cycle storage; and have safe and convenient access to

public transport.

It is considered that River Gipping is a significant barrier to sustainable travel opportunities

from the site to the north, where employment opportunities exist within the Sugar Beet site,

and Boss Hall Industrial Estate. Furthermore the river represents a physical barrier to the

residential areas north of Sproughton Road in gaining access to Chantry Park.

Currently access to major employment and service areas north of the site would likely be

undertaken by private car, as the closest convenient place to cross the River Gipping is

London Road/Yarmouth Road, some 870m away from the site. A trip to Boss Hall Industrial

Estate for example, typically would take 40 minutes to walk or 12 minutes by car. More

confident cyclists may prefer cycling, at approximately 10 minutes but this on-carriageway

lengths including Hadleigh Road with significant numbers of goods vehicles.


The site is in a highly sustainable location, near to a range of primary and secondary

services and facilities, employment opportunities and education. There are opportunities to

walk and utilise the public transport network from the site and thus reducing the need to

travel by car.

The principal access to the development is proposed to be centrally located onto Hadleigh

Road, very much in line with the application previously considered for the Arclion House

development (IP/16/00576/OUT) awaiting determination but with a resolution to grant outline

permission.

There is an Air Quality Management Area (AQMA) within the Yarmouth Road/Bramford road

junction therefore it is likely that there is potential for this development to result in additional

traffic within the AQMA. The site is strategically located for a crossing over the River Gipping

and this would allow for movement north-south without the need to use the congested areas

around Yarmouth Road. The applicant has agreed to provide a landing place for a bridge

within the site in order that a bridge be built at a later date which connects the north and

south sides for pedestrian and cyclists. This would facilitate access to Chantry Park and

other amenities for people from north of the river and vice-versa for the wider community

south of the river. This could also facilitate access to the riverside path to Sproughton from

the site. Exact details of the bridge and funding of it would be subject of separate

applications; however the landing place and link through to Hadleigh Road, and Chantry

Park would be secured should outline planning permission be granted.

The Highway Authority has requested a range of measures in order to ensure that the site iseasily accessed by a range of measures, and that it is safely accessible. These arecomprised of:-

The reservation of land (to be agreed by the County Council) on the site necessary to

construct and land the pedestrian and cycle bridge, and the transference of the land

to the County Council for £1 to allow for the delivery of the bridge. This would be

dependent on delivery of the Sugar Beet Factory site.

A pedestrian crossing and traffic speed reduction measures as necessary, to be

provided on Hadleigh Road to the west of the site. Measure to be subject of a

contribution of £80,000 to cover the cost of implementing these measures.

A scheme of cycle improvements to be implemented along Hadleigh Road near to

the site.

A contribution of £10,000 to be paid to the County Council towards Traffic Regulation

Orders near the site and including a 20mph Zone Order on the site.

The kerbs at three local bus stops to be improved with easy access kerbs to the

satisfaction of the County Council.

A Travel Plan Evaluation and Support Contribution of £1,000 per annum from

occupation of the 100th dwelling shall be paid to the County Council for a minimum of

five years, or one year after occupation of the final dwelling, whichever is longer.


A Travel Plan Implementation Bond, or Cash Deposit of £91,721 (£717 per dwelling –

based on the estimated cost calculated by Suffolk County Council of fully

implementing the travel plan) shall be paid to the County Council.

The applicant has agreed to the above provisions in full, which are proposed to be includedin the S.106 legal agreement as detailed in the report below and recommendation Heads ofTerms.

The transport assessment submitted with the application has been assessed by theHighways Authority and it is acknowledged that the trip generation of the proposeddevelopment is likely to be less that when the site was in use as an employment site.However this is more than 10 years ago therefore there will be an increase in traffic. Thejunction design would require significant visibility splays (90 metres) to be included into thedesign.

Further to detailed analysis of the scheme including indicative layout no objections havebeen received from SCC Highways to the scheme. Consequently the main matter of theapplication (Access) is considered to be acceptable having regard to policies SP9, CS5, andDM17.

Babergh District Council are satisfied with the comments received from SCC Highwayssubject to the securing the aforementioned road improvements and financial contributions.

Affordable Housing

Permission is sought for a development of 128 dwellings – 105 of which would be located

within Ipswich Borough. Policy CS12 seeks to ensure that a choice of homes is available to

meet identified affordable housing needs in Ipswich. New developments of 15 dwellings or

more should provide for at least 15% on-site affordable housing by number of dwellings. At

least 80% of affordable housing provision shall consist of affordable rented homes or homes

for social rent. The Council will only consider reducing the requirement for the proportion of

affordable housing on a particular development site, or amending the tenure mix to include

more intermediate housing, where: a) alternative provision is made by the developer; b) an

accepted independent review of development viability finds that alternative provision is

justifiable; and c) the resultant affordable housing would be sustainable in social terms.

Babergh District Council similarly requires affordable housing to promote mixed

communities, however at a rate of 35%. Any developments providing less that this figure will

again be dependent on developer viability being demonstrated (BDC policy CS19).

For the development 105 units proposed within the Ipswich Borough part of the site this

would equate to 15.45 affordable dwellings, and within the Babergh part of the development

area would equate to 8.75 dwellings.

A rounded total for the entire development would equate to 24 affordable dwellings.

In this case the applicant proposes zero affordable housing for the scheme. Members are

requested to refer to confidential purple pages for full reports regarding viability which has

been submitted by the applicant prepared by Housing Expectations, and which has been

independently assessed by the District Valuers Service (DVS) on behalf of the LPA, whose

report can also be viewed in the confidential pages.


The development is brownfield land and is subject to numerous financial constraints to

remediate the site ready for building houses. These include demolition, asbestos removal,

piling, service connections, site wide drainage, pumping and storage tanks, and a financial

covenant.

In summary whilst in outline form only, the applicant has provided additional detail based on

their development delivery assumptions at this stage. These include a breakdown of the

market housing mix as follows.

Ipswich –

Type No. of units Average size Total size

Ipswich

Type 1 – 2 Bed 32 79.1 2,530Type 2/3/4 – 3 Bed 48 93.0 4,464Type 5 – 3 Bed 14 97.0 1,358Type 6 – 3 Bed 4 94.3 377Type 7 – 4 Bed 2 115.2 230Type 8 – 4 Bed 2 129.4 259FOG – 2 Bed 1 70.3 70

Babergh

Type 1 – 2 Bed 2 79.1 158Type 3 – 3 Bed 6 93.0 558Type 4 – 3 Bed 6 115.2 691Type 6 – 3 Bed 7 94.3 660Type 7 – 4 Bed 4 115.2 461Type 1 – 2 Bed 2 79.1 158

Total Residential 128 11,816 sqm

Checks have been undertaken in accordance with the requirements of the RICS standards

and have revealed no conflict of interest. DVS has had no other previous material

involvement with the property or site evaluation.

The DVS have based their assessment establishing the entire build cost, and whether

following sales revenue, the residual land value is met. With regards to the build costs the

following are included:- Base build cost; Abnormal other costs (such as site remediation etc);

Contingency; Professional fees; Section 106 / CIL costs; Sales and Marketing Fees;

Development Programme; Finance costs (development borrowing for cash flow at 7%);

Developers profit (20%); and Land Value.

The DVS has stated that on the basis of an all private development scheme (with no

affordable housing) on a scheme with this many abnormal costs the risks would be high and

a 20% profit would be expected to make the scheme viable in the current market. The

current scheme as detailed would result in a development profit of 17.8% profit which would

be below that anticipated for a scheme with this level of risk.

Negotiations have been had with regards to other financial contributions associated with

development of the site for the delivery of necessary infrastructure, as to whether certain


other financial demands can be reduced so that the developer could attain 20% profit.

However it is considered that the full costs of these should be met. The applicant has agreed

to the infrastructure costs and Heads of Terms as set out in the remainder of the report.

Whilst no affordable housing is proposed officers are satisfied that the development and

delivery of the site would be jeopardised if affordable housing was required, it is estimated

that a build time of 5 years is proposed in 5 phases. A review mechanism is therefore

recommended as part of the legal agreement at the end of phase 3 and 5 to ensure that if

the site/market conditions improve during the construction phase that financial contributions

can be made towards affordable housing.

Provided the review mechanism is included within the legal agreement the proposals would

be acceptable having regards to policy CS12 and BDC policy CS19.

Infrastructure requirements

The National Planning Policy Framework (NPPF) paragraph 204 sets out the requirements

of planning obligations, which are that they must be:

a) Necessary to make the development acceptable in planning terms;b) Directly related to the development; and,c) Fairly and reasonably related in scale and kind to the development.

The Ipswich Core Strategy was adopted in December 2017, and includes the followingobjectives and policies relevant to infrastructure: Objective 9 seeks to retain and providehigh quality schools, health facilities, sports and cultural facilities and other key elementsof community infrastructure. Policy CS17 requires all development to meet the on and offsite infrastructure requirements needed to support the development and mitigate theimpact of the development on the existing community and environment.

Babergh District Council Policy CS21 requires similar provisions to meet the necessaryinfrastructure needs. With regards to infrastructure provision much of the BaberghDistrict Councils infrastructure provision is secured through the Community InfrastructureLevy, whereby an adopted list of infrastructure is provided for through a fixed ratepayment levy on all new buildings. The figures for CIL are based on floor area of thedwellings – in this case a chargeable rate of £115 per sq.m, which would be chargeableat Reserved Matters stage once final dwelling sizes are known.

Under regulation 123(2) of the Community Infrastructure levy Regulations (2010)Babergh DC are required to publish a list of infrastructure to be funded by the levy.These details are set out below:-

Provision of passenger transport Provision of library facilities Provision of additional pre-school places at existing establishments Provision of primary school places at existing schools Provision of secondary, sixth form and further education places Provision of health facilities Provision of leisure and community facilities Provision of ‘off site’ open space Strategic green infrastructure (excluding suitable

alternative natural greenspace) Maintenance of new and existing open space and strategic green infrastructure

Strategic flooding Provision of waste infrastructure


NPPF paragraph 72 states that the Government attaches great importance to ensuringthat a sufficient choice of school places is available to meet the needs of existing andnew communities. Local planning authorities should take a proactive, positive andcollaborative approach to meeting this requirement, and to development that will widenchoice in education. The NPPF at paragraph 38 states that for larger scale residentialdevelopments in particular, planning policies should promote a mix of uses in order toprovide opportunities to undertake day-to-day activities including work on site. Wherepractical, particularly within large-scale developments, key facilities such as primaryschools and local shops should be located within walking distance of most properties.

The local catchment schools are Ranelagh Primary School, and the high school would beeither Westbourne Academy or Chantry Academy, both being approximately the samedistance from the site. SCC currently forecast to have no surplus places at the catchmentprimary school and Chantry Academy; however Westbourne Academy has some surplusplaces to provide places for the pupils generated from the development. Therefore, SCCis seeking contributions against this particular proposal as set out in the table below.

The scale of contributions is based on cost multipliers for the capital cost of providing aschool place, which are reviewed annually to reflect changes in construction costs. Thefigures quoted will apply during the financial year 2016/17 only and have been providedto give a general indication of the scale of contributions required should residentialdevelopment go ahead. The sum will be reviewed at key stages of the applicationprocess to reflect the projected forecasts of pupil numbers and the capacity of theschools concerned at these times. Once the Section 106 legal agreement has beensigned, the agreed sum will be index linked using the BCIS index from the date of theSection 106 agreement until such time as the education contribution is due. SCC has a10 year period from completion of the development to spend the contribution oneducation provision.

Education for early years should be considered as part of addressing the requirementsof the NPPF ‘Section 8 Promoting healthy communities’. It is the responsibility of SCC toensure that there is sufficient local provision under the Childcare Act 2006. Section 7 ofthe Childcare Act sets out a duty to secure free early years provision for pre-schoolchildren of a prescribed age. The current requirement is to ensure 15 hours per week offree provision over 38 weeks of the year for all 3 and 4 year-olds. The Education Act2011 amended Section 7, introducing the statutory requirement for 15 hours free earlyyears education for all disadvantaged 2 year olds. Through the Childcare Act 2016, theGovernment will be rolling out an additional 15 hours free childcare to eligiblehouseholds from September 2017. There are 5 providers in this ward. Buttons andBows, The Oaks Primary, Ranelagh Primary, The Children’s Triangle and a childminder.We forecast a deficit of – 212 places in this ward.

Each dwelling is expected to generate the need for 2.8 library items per annum (Suffolkstandard level of stock per 1000 population is 1,174, CIPFA Library Survey 2015). Theaverage cost of library stock in Suffolk is £5.66 per item. This includes books andphysical non-book items, like spoken word and music CDs, and DVDs, as well as dailynewspapers and periodicals. This gives a cost per dwelling of 2.8 items x £5.66 = £16per dwelling.

The applicant has agreed to enter into a legal agreement to secure the entire infrastructure

requirements derived from the development, and therefore having regards to policy CS17

the proposals would be acceptable.

Heads of Terms are as follows:


NHS Local provision £ 55,200.00

SCC Education Primary £ 316,706.00

SCC Education Secondary £ 183,550.00

SCC Pre-School £ 60,910.00

SCC Libraries £ 1,648.00

SCC Highways Bus infrastructure £ 7,500.00

SCC

Highways

Transfer of land toSuffolk County Councilto accommodate bridgelanding point for fee of -£ 1.00

SCC Highways pedestrian crossing £ 80,000.00

SCC Highways TRO £ 10,000.00

SCC Highways Travel Plan monitoring £ 5,000.00

SCC Highways Travel Plan bond £ 91,721.00

IBC Open Space Provision £ 137,768.00

IBCOpen SpaceMaintenance £ 10,184.00

IBC Habitats RegulationsAssessment £204.99 per dwelling £ 21,523.95

Total £ 981,709.95

Any planning obligation under section 106 of the 1990 Act will also be subject to BaberghDistrict Council’s final approval. However it is noted that the development site lies within thehigh value zone for BDC CIL Charging, and would be subject to CIL at a rate of £115m²(subject to indexation), which as described above would secure much of the necessaryinfrastructure derived from the Babergh part of the development site.

Land contamination

A phase 1 land contamination survey has been submitted with the proposals and findings

accepted. Given the site’s historic uses risks have been identified associated with the quality

of the shallow soils and the potential for this to affect future residents (interacting with soil in

gardens etc.) as well as risks posed to the water quality of the River Gipping.

Policy DM26 requires that planning permission for any development (including change of

use) will not be permitted where it would likely cause material nuisance to the proposed,

existing and / or adjacent users, residents, occupiers or where it is liable to be detrimental to

human health. Development which could itself be significantly adversely affected by the

conduct of established or potentially noisy or polluting uses nearby will not be permitted.

IBC Environmental Health request a Stage 2 survey is necessary including site specific

investigation. All of the relevant mitigation to be implemented in full prior to occupation. Any

unidentified contamination found within the site not previously identified, details will need to

be provided to the LPA and works stop on site, until necessary mitigation is specified and

implemented.

Implementation of the approved contamination mitigation (in association with necessary

drainage strategy and design) will ensure that the site is safe for residential occupation, and


that the River Gipping is not contaminated as a result of surface water drainage. The

proposals would therefore be acceptable having regards to Policy DM26.

Sustainability / Flood Risk and drainage

The site slopes from Hadleigh Road down to where it meets the River Gipping. The

northernmost part of the site sits within Flood Zones 2 & 3 however the developable area will

be within Flood Zone 1. Nevertheless the site could be subject to flood risk owing to the

proximity of the River Gipping. The Environment Agency recommends that minimum floor

levels are provided within the habitable rooms of the development, and that an emergency

access/egress plan is submitted for approval and distributed to the future occupants.

Policy DM4 requires that development does not increase the overall risk of all forms of

flooding in the area or elsewhere through the layout and form of the development and

appropriate application of Sustainable Drainage Systems (SuDS); it will be adequately

protected from flooding in accordance with adopted standards wherever practicable; it is and

will remain safe for people for the lifetime of the development; and it includes water

efficiency measures such as rainwater harvesting, or use of local land drainage water where

practicable.

Drainage proposals have been submitted which indicate that a series of pipes currently drain

the site into the River Gipping. It is proposed that areas deemed clear of contamination, and

with suitable infiltration rates, are to be drained using permeable paving and geo-cellular

soakaways (SUDs). The remainder of the site would be drained via pipes into the River

Gipping. Flow speeds would be reduced by means of a series of attenuation tanks within the

site and a balancing pond within the northern greenspace of the site. The pond could act to

improve biodiversity within the natural landscaping that is to be retained.

Foul drainage would be dealt with by a pumping station proposed in the north east of thesite. Indicative plans indicate a buffer zone around the pumping station in order to retainlevels of residential amenity, however this would be considered as part of a reserved mattersapplication relating to layout.

The SCC Flood and Water Management team consider that details are still required with

regards to precise water pollution measures; the treatment pond capacity; soakage test

details; care home surface water drainage strategy; and maintenance details. The applicant

is in discussions with SCC regarding the details and officers will update the meeting on

these matters which relate to specific design.

Provided the surface water drainage strategy is agreed the proposals will be acceptable

having regards to policy DM4.

Indicative layout and design

To precise layout and design of the scheme will be determined at Reserved Matters Stage,

whereby matters covering Appearance, Scale, Layout and Landscaping will be specific to

these submissions.

The phased parameter plan indicates 5 different phases of development. Phase 1 with up to

9 dwellings, phase 2 with up to 38 dwellings, phase 3 with up to 56 dwellings, phase 4 with

up to 25 dwellings and phase 5 with the care home. Phases 1, 2, and 3 would be within

Ipswich Borough and phases 4, and 5 within Babergh.


The indicative plans show a main access road from Hadleigh Road going north along the

centre of the site with eastern loop road. The road terminates within Babergh phase 4 but

allows pedestrian cycle access back onto the main access spine road. The layout as

indicated is considered to be permeable for pedestrian and cyclists and offer and appropriate

means of access to the respective dwellings, and for servicing.

The phasing plan does offer some flexibility which shows development levels ‘up-to’ the

number of houses. The variety and type of dwelling has not been precisely agreed at this

stage however the indicative details show compliance with Policy DM30 and DM3 having

regards to internal and external amenity spacing.

The approximate density would be 30 dwellings per hectare which would be acceptable

having regards to the prevailing character of the area.

Public open space

Policy DM29 requires that new developments need to meet the needs of their occupiers and,

where appropriate, contributions are provided to strategic accessible natural greenspace. In

all new residential developments of 15 dwellings or more (or on sites of 0.5ha or more), at

least 10% of the site area, or 15% in high density residential developments, should consist of

on-site green space that is usable by the public, which will contribute to meeting the overall

requirement. Where possible, public green spaces should be well overlooked, and the

provision within large-scale developments should be distributed throughout the site.

These developments would also be expected to mitigate their own impact through the

provision of the various open space and facility typologies, of which 10 are identified. Where

the need for provision is triggered, there will be a presumption in favour of on-site provision.

Where this is not practicable or the Council prefers enhancement opportunities at existing

facilities, or the area generated by applying the standard is smaller than the Council’s

minimum size, then an in lieu contribution to new or existing off-site provision should be

secured through a planning obligation. There may be circumstances where development

would more suitably accommodate greater provision of one typology at the expense of

another. Such circumstances will be considered on their merits.

Development proposals should be located within set proximity standards of different

typologies of public open space such as Parks and Gardens; Amenity Green Space; Natural

and Semi-natural green space; Outdoor sports; Children’s play areas; Provision for Young

People; Allotments; Cemeteries and Churchyards; Ecological Networks; and Civic Spaces.

In this instance the site is outside of the catchment for a number of the aforementioned

typologies and a commuted sum would be required to improve and enhance existing

facilities.

In this case the above policy requirements within the site not met on site and in many cases

accommodating some of the identified criteria would take a significant portion of the site area

up, thus reducing viability to undeliverable levels. The site is directly opposite Chantry Park

where a number of the necessary public open space (POS) typologies can be found. It is

considered that, in accordance with the Public Open Space SPD a commuted sum be

secured to address the onsite shortfall. In this case as identified by colleagues in the Parks

and Landscape department the proposals would attract £137,768 for enhancements of the

different typologies and £10,184 for maintenance.


The policy requirements for public open space are for 10% of public open space within the

development itself. This should consist of on-site green space that is useable by the public,

which will contribute to meeting the overall requirement. Public open space should be well

overlooked and distributed through the site. The indicative plans show a series of open

space areas located around protected trees on the west side of the site, centrally located,

and within the northern bank of the River Gipping. Whilst levels are not specifically within the

IBC part of the site 10% is provided broadly across the site as a whole. This would be well

overlooked by adjacent housing. A green spine road can also be accommodated with good

levels of tree planting throughout the site. A management plan would cover maintenance of

the landscaping which would be subject to detailed design considerations at Reserved

Matters Stage.

The applicant has agreed to meet the necessary contributions as set out in the Infrastructure

section of this report and therefore the proposals would be acceptable having regards to

policy DM29.

Biodiversity

Policy DM31 seeks to conserve the nature conservation of County Wildlife Sites, Local

Wildlife Sites as identified in the proposals map and the Suffolk Biodiversity Action Plan. In

this case the site is within 1km of the Stour and Orwell Special Protection Area (SPA), a

European designated site and therefore has the potential to affect its interest features. Under

the Conservation of Habitats and Species Regulations 2010 a Habitats Regulations

Assessment is required. This has been undertaken by IBC to ascertain whether off site

mitigation is the appropriate method of dealing with associated impacts that the development

might have on the protected area.

In order to satisfy the requirements of the Habitats Regulations for this proposal, the Local

Planning Authority needs to consider the impacts arising from the development and provide

evidence to demonstrate that any proposed mitigation measures will be able to fully mitigate

for these impacts, given that the coast has a considerable attraction for visitors and a

proportion of new residents will be likely to travel to designated sites.

Under normal circumstances Natural England are of the opinion that mitigation usually

requires more than one type of approach and is likely to require green infrastructure

provision as well as visitor access management measures on designated sites to address

any in-combination impacts of development. Appropriate requirements are included in the

s.106 Heads of Terms in accordance with the HRA.

On site biodiversity is limited to the fringe of the site with trees around the periphery. Those

trees along the western boundary (BDC) and central boundary (IBC) are protected and to be

retained. The remainder of the site is mainly hard surfaced with the remaining buildings etc.

The northern edge adjacent to the river corridor will be retained and represents and

important part of this wildlife corridor. Ecological enhancements will be required as part of

the measures and further mitigation are required.

Habitats Regulations Assessment has been undertaken and as such the developer agrees

to pay the necessary financial contribution towards protection and mitigation of the protected

Stour and Orwell Estuaries.

The proposals would comply with policy DM31.


Other matters

Limited public representation has been made to this application, however, matters raised

regarding traffic generation; congestion and impact on local services have been addressed

in this report. No objections have been received from SCC (as the Highways Authority and

Local Education Authority) with regards to impact on the highway network in terms of safety

or congestion, nor with regards to impact on schools (provided s.106 contributions are

made).

With regards to impact from the scale of the development from the proposed nursing home

(in Babergh) this matter would be dealt with at the Reserved Matters stage. Nevertheless the

indicative plan show the nursing home being some 43 metres from the nearest existing

residential property in Elton Park, with a large bank of protected trees growing between the

sites. It is not anticipated that the indicative 4-storey building would have a significant

adverse impact on the residential amenity of the occupants.

7. Conclusion

The proposed scheme would result in the principle of residential development being

approved for this long-standing brownfield site, which in turn would assist in meeting the

need for housing within Ipswich Borough and Babergh District. The outline details provided

would be acceptable having regards to the requisite adopted policies relating to the quantity

of development, uses proposed and access arrangements.

Whilst the proposals would not provide any affordable housing in this case, the development

would provide financial contributions towards the necessary infrastructure requirements

derived from the development. Contributions would be obtained by means of S106

agreement (IBC) and CIL (BDC), and it is recommended that a financial review be written

into the legal agreement, to ensure any changes to the financial situation are appraised.

The development would be sustainable in this location and meet national planning policies

and guidance. It would be supported by Local Plan polices and the site is an allocated

housing site. The development would also be acceptable having regard to the Babergh site

allocation. The detailed layout, appearance, scale, and landscaping would all be subject of

Reserved Matters applications in accordance with the agreed phasing strategy and details

set out in proposed planning conditions.

The development would generate off-site infrastructure requirements necessary to support

the development and thus infrastructure contributions are necessary to make the

development acceptable. The proposals would comply with Ipswich Core Strategy policies

CS1, CS2, CS4, CS5, CS7, CS12, CS17, DM1, DM2, DM4, DM5, DM10, DM17, DM18,

DM26, DM29, DM30, DM31, DM33, and Policies CS2, CS12, CS13, CS14, CS19, CS21,

EM02, CN03, CN04, RE14, TP16, HS01 of the Babergh Local Core Strategy (adopted and

saved).

item 4 application no. ip/16/01220/out 4.pdf · item 4 application no. ip/16/01220/out ward:...

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