Suffolk Coastal Local Plan - Final Draft

Document Section Final Draft Local Plan 12 Strategy for Communities Surrounding Ipswich Recreation and Open Space in Rushmere Policy SCLP12.22: Recreation and Open Space in Rushmere [View all comments on this section]
Comment ID 1390
Respondent Ipswich Town Football Club and… [View all comments by this respondent]
Agent Boyer Planning (Bailey, James)
Response Date 25 Feb 2019
Do you consider this part of the Plan has met the tests of soundness? No
Details of Representation


On behalf of Ipswich Town Football Club (ITFC), Boyer has reviewed the Final Draft Local Plan document prepared by Suffolk Coastal District Council.

Representations have previously been submitted as part of the Issues and Options Consultation, and then again to the First Draft Local Plan Consultation, specifically in relation to ITFC and the University of Suffolk (UOS), detailing the desire to develop a world class sports science educational and training facility.

As previously set out as part of the First Draft Representations, ITFC are actively seeking to promote and better utilise the land at Ipswich Town Football Club Training Ground and Academy, off Playford Road, Rushmere St Andrew (Site reference numbers 1060 and 953). A site location plan is included in Appendix 1.

The proposals for the site centre around working towards the creation of a world class sport and education hub; with enabling residential development on derelict land to help facilitate these improvements.

ITFC are keen to explore the possibility for some form of residential accommodation on the site. This would be to house scholars (age 16-18) and the caretaking / pastoral / safeguarding staff of the ITFC sporting academy due to the costs and distance challenges of alternative accommodation. This would be key for any proposals in terms of the attractiveness of the programme to scholars and their parents/guardians compared to other clubs that have on site accommodation, and is needed to protect the long term sustainability of the programme. Recent public issues in the football world, regarding young people, have made this a more relevant issue today than it has ever been in the past. Therefore a comprehensive approach to the facilities and the proposals would be paramount.

These representations refer to related policies and development potential of the sites. Our comments are set out below, and follow the chronological order of the sections and policies within the consultation document.

We have also resubmitted our previous representations (Appendix 2), which provides further background information and details on the proposals, alongside a supporting Development Brief.

Section 12 Area Specific Strategies

Policy SCLP12.22 Recreation and Open Space in Rushmere

It is understood that the local community seek to protect Rushmere St Andrew from the pressure of coalescence, and this policy has been included in previous Local Plans. The policy seeks to protect the land for the provision of sport and recreational opportunities, which is both public and privately accessible, and that it is retained for the benefit of the community as well as reducing the coalescence. This is noted and understood. However, there has been no assessment of the land in this policy as part of this Local Plan, and whether it actually still performs the same purpose as originally intended.

It is also noted that the policy text has been amended. However there is no explanation for the amended text, and as mentioned above, it is not properly supported by proportionate evidence. This includes:

  • The policy text includes reference to ‘retain separation and natural open spaces and support biodiversity and wildlife networks’. However, we argue this is not the case. There are no natural open spaces, as the area forms part of the ITFC Training Ground and Academy. It is a maintained space used for the clubs purposes. Therefore, there are limited biodiversity and wildlife networks.
  • The policy text also refers to ‘Land between Ipswich and Rushmere village, in its undeveloped form, presents an important green space between communities whilst contributing to the recreational needs of the District and Ipswich Borough’. However, the land is not ‘undeveloped’ as described, and it does not contribute to the recreation needs of the district, as it does not provide a publically accessible open space. It is considered that the training grounds, the academy buildings, access points, and former employment social club facilities, actually constitute ‘Brownfield’ land. This is explained in further detail below.
  • Furthermore, there has been no consideration of whether the designation as recreation and open space should still be protected as such. Sport England have confirmed during pre-application discussions that not all of the site provides the function of sports / open space, and could be better utilised for residential development. This was also confirmed as part of their comments on the First Draft Local Plan, where Sport England stated we have indicated that we would not object to small scale loss of the non-sporting land south of Playford Road, if this enabled investment into the existing sports facilities within the remainder of the site’.
  • It is also considered that some parcels of the designation could come forward for development and still retain the settlement separation between both Ipswich and Rushmere.

It is noted the Sustainability Appraisal sets out that the policy protects the existing sports and recreation facilities, and limited the loss of green, undeveloped land. However, as set out above this is not reflective of the uses of the land, and it does include previously development land. There is no supporting evidence referred to within the Sustainability Appraisal, and no alternative options considered for the policy.

This policy includes our client’s land at Ipswich Town Football Club Training Ground and Academy, off Playford Road. Whilst the majority of the site is used for ITFC and playing pitches, it is privately owned so it is not accessible to the public. Furthermore, not all of this land forms part of a sport and recreation use, and includes vacant, derelict, brownfield land on the east of Playford Road.

This part of the land historically formed an area of the Fisons Sports Club with a pavilion, bowling green, and tennis court. However, despite the wider site being fully utilised by ITFC, this part of the site has not been used by ITFC for over 25 years, since the club originally leased the wider site in 1993. ITFC have been committed to investment in the club facilities, however this part of the land was never seen as a suitable investment opportunity for the training ground or the academy. This area of land therefore remains empty and private, and does not fulfil any useful function at the current time.

It stands in a derelict state, with a partly demolished pavilion building, and unusable tennis courts. Due to the nature of the land and its proximity to existing residential dwellings, it is incapable of forming part of a playing pitch or other ancillary use for the site. As a result the land has been largely unused, and it does not form part of any public open space or make any sports provision. ITFC previously had no plans for using this area of land for training or sports purposes, therefore it remains in its vacant state moving forward. Initial discussions with Sport England, as confirmed above, have agreed the site does not provide any sport or recreation use, and alternative uses may be possible if it included improvements to better located sports facilities.

This information was submitted as part of the previous representations for the Local Plan, however, it is not considered this has been reflected in the Final Draft. It is noted SCDC’s Consultation Statement refers to our previous representations submitted, but SCDC state that their view is “…the policy remains appropriate in preventing the coalescence of Ipswich and the village of Rushmere, whilst supporting continued sports use of the land. It is considered that the area as a whole meets the objective of the policy.” However, there is no supporting evidence to support this view and there appears to be no consideration of the change in circumstances, in terms of the derelict land, by SCDC. For these reasons it is considered the policy is unjustified and it is not consistent with national policy. Furthermore, there appears to be repetition with policy SCLP10.5 Settlement Coalescence, and this does not accord with the NPPF Paragraph 16(f) which states Plans should avoid unnecessary duplication of policies that apply to a particular area.

The proposals for the vacant part of the site include residential development, to assist ITFC in continuing to invest in the facilities for the club and the development of the Academy. The proposals for a state of the art sport and education hub would not materially reduce or compromise the open gap between the settlements, and therefore would retain the character and identity of the area. Furthermore, the development would enable additional investment into the sport facilities and also the University, so it would still support the principle of providing for sport and recreational opportunities.


Please set out what change(s) you consider necessary to make the Local Plan legally compliant or sound

In light of the above comments, we suggest the following amendments to make the policy sound and reflective of the circumstances:

12.204 Within this part of the District, the pressure of settlement coalescence is seen most prominently. Some communities are separated from others by large areas of open space, sports facilities, previously developed derelict land, and countryside, whilst others blend into one another. Previous Local Plans sought to protect the open space between Ipswich and Rushmere Village through a specific policy and this is continued in this Local Plan. Land in this area is to be retained for sports and sports associated requirements, associated educational and academy facilities, and enabling development, and recreational uses primarily which also restricts inappropriate other forms of development in this location. As identified earlier in the Plan, opportunities for expanding the ITFC Training Ground and Academy and the emergence of the University of Suffolk will be explored and encouraged. Over the plan period, the provision of sport and sports associated educational facilities and enabling residential development on derelict land, and recreational opportunities, both public and privately accessible, will be supported and retained for the benefit of the community as well as reducing the coalescence of settlements.

Policy SCLP12.22: Recreation and Open Space in Rushmere

Land is identified near Rushmere Street as shown on the Policies Map to retain settlement separation and the sports facilities. natural open spaces and support biodiversity and wildlife networks. Land between Ipswich and Rushmere village, in its undeveloped form, presents an important green space between communities whilst contributing to the recreational needs of the District and Ipswich Borough. Proposals will only be granted for sports ground and sports associated requirements and educational facilities, or other associated recreational uses. Enabling development, on derelict land that would not impact on the settlement separation, will be permitted where there are clear benefits for delivering the sports and associated education facilities.

If your representation is seeking a change, do you consider it necessary to participate in the public examination?
  • Yes, I wish to participate at the oral examination
If you wish to participate in the public examination, please outline why you consider it to be necessary:

To discuss the concerns regarding soundness of the Plan in full, and how this could be resolved.

Being kept informed
  • Yes, I would like to be kept informed