Application No. IP/13/00605/FUL

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1 Item 11 Ward: Proposal: Address: Applicant: Agent: ALEXANDRA Application No. IP/13/00605/FUL Conversion of existing building into 3x self contained flats with associated internal and elevational alterations. 1-1A Dove Street Mr S Curtis Last And Tricker Partnership 94

2 Planning permission be refused for the following reason:- 1. Having regard to the restricted floor areas indicated for the one bedroom flats in addition to the inadequate area and quality of private amenity space available, the proposed conversion of the existing building into three flats would be overdevelopment of the site and would result in a substandard and unsustainable living environment for future residents and would be contrary to Policies DM 30 and DM3 of the Ipswich Core Strategy and Policies DPD and one of the core planning policies of the secure high quality design and a good standard of 1. Proposal The proposed development is for the conversion of the existing two storey commercial building into 3 no. flats. Ground Floor:- 2 no. x 1 Bedroom Flats (floor area c. 34m² each) with access to communal courtyard (c.9m²) First Floor:- 1 no. x 2 Bedroom Flat with access to proposed roof terrace (c.18m²). There is an existing garage with direct access from street level, proposed for use as cycle parking area for all three flats. This is a resubmission of a recently refused planning application Register Index no: IP/13/00293/FUL, with revised elevation changes to address previously identified desig n concerns in the Conservation Area. 2. Background Permission for a change of use from a storage building to 2 no. self contained flats was originally permitted in 1999 and renewed on three further occasions over a 13 year period, the last renewal was approved under ref. 12/00817/FUL on 13 th December A planning application on site was recently refused under 13/00293/FUL for existing building into 3 no. self-contained flats with associated internal and elevational. The reasons for refusal were: inadequate private amenity space available, the proposed conversion of the existing building into three flats would be over-development of the site and would result in a substandard and unsustainable living environment for future residents and would be contrary to Policies DM30 and DM3 of the Ipswich Core Strategy and Policies DPD. 2. Having regard to the location of the existing building within St. Helens Conservation Area, the design as proposed, in particular the fenestration details would not protect or enhance the character and distinctiveness of the area and would be contrary to Policy DM5(e) and DM8 of the Ipswich Core Strategy and P 95

3 The current submission sought to address these reasons for refusal with changes to the fenestration details. 3. Consultations Waste Management - I am unable to comment on the above application as there is no reference to where the bins would be stored throughout the week or placed for collection at the roadside of the development as per my previous memo on previous application. Please refer this important issue to the developers for rectification ASAP. Environmental Health - Pollution Contamination - It would be advisable to undertake a contaminated land risk assessment, advice is available on the web site. This should include in the first instance an enviroscreen and site walkover. Noise - There are a number of commercial premises in the area including pubs and hot food takeaways, a noise assessment should be undertaken to ensure that noise from these premises will not adversely affect the residents of the converted premises. Environmental Health - Private Sector Housing - Based on the information provided, as long as the conversion meets building control standards we have no comments. However, in the event of a fire it would appear that the occupants on the first floor have to pass through a risk room (i.e. the kitchen/dining room) to escape. In light of this, we would advise that the layout is amended to enable the occupants of this flat to exit the building without having to pass through a risk room. Conservation & Urban Design - The design incorporates most of the changes requested in our response to IP/13/00293/FUL and now reflects the transitional nature of the area (between the conservation area street and the more robust, industrial setting of the college buildings). The edge cladding of the retained garage gable (fronting the proposed terrace) is not described in the drawings it would be useful to have this information so that the design (which includes the glazed spandrel) can be properly understood. Recommendation: Approval, with additional detail as described above. Representations No representations have been received. 4.Policy The following policies of the adopted Ipswich Core Strategy Policies & Development Plan Document (2011) are relevant:- Policy CS2: The Location and Nature of Development The regeneration and sustainable growth of Ipswich will be achieved through: h. Focusing most new residential development and community facilities into the town centre, the Waterfront and Ipswich Village, and into or within walking distance of the town's district centres; 96

4 i. Focusing major new retail development into the Central Shopping Area; j. Focusing new office, hotel, cultural and leisure development into Ipswich town centre; k. Promoting a strategic employment site support economic development and jobs growth; l. Directing other employment uses (B1 except office, B2 and B8) to employment areas distributed in the outer parts of the Borough; m. Dispersing open space based (non-commercial) leisure uses throughout the town; and n. Development demonstrating principles of very high quality architecture and urban design. In addition to the above locations, a sustainable urban extension to north Ipswich is planned subject to the prior provision of suitable infrastructure (see Policy CS10). Major developments within the town centre, Ipswich Village, and district centres should incorporate a mix of uses to help achieve integrated, vibrant and sustainable communities. Major developments are defined as commercial developments of 1,000 sq. m or more or residential developments of 10 units or more. The mix will consist of at least two uses, with the lesser use consisting of at least 20% of net floorspace. Exceptions may be made for large offices or education buildings for a known end user. Development densities will be high in the town centre, Ipswich Village and Waterfront, medium in the rest of IP-One and in and around the district centres, and low elsewhere. Policy DM3: Provision of Private Outdoor Amenity Space in New and Existing Developments To ensure that new residential developments deliver a suitably high quality and environmentally sustainable living environment all such developments will be required to incorporate well designed and located private outdoor amenity space of an appropriate type and amount. Provision will be in accordance with the following standards unless this would unavoidably conflict with the need to meet other density and urban design requirements of the plan or an applicant is able to demonstrate that a lower figure would be acceptable having regard to the particular circumstances of the proposals. In all cases applicants will be expected to demonstrate that adequate provision of private outdoor amenity space will be provided for the likely occupancy of the proposed dwellings. For all houses, bungalows, or ground floor maisonettes with 3 or more bedrooms a minimum rear garden area of 75 sq. m. For all houses, bungalows, or ground floor maisonettes with 1 or 2 bedrooms a minimum rear garden area of 50 sq. m. For all apartments or upper floor maisonettes an average of 25 sq. m of private outdoor amenity space. 97

5 Policy DM5: Urban Design Quality The Council will require all new development to be well designed and sustainable. In Ipswich this will mean: a layouts and designs that provide a safe, attractive, permeable, legible and useable public realm for all users, which is pedestrian and cycle orientated; b. areas which function well and where possible integrate residential, working and community environments and fit well with adjoining areas; c. the promotion of safe and secure communities; d. greener streets and spaces to contribute to local biodiversity, visual amenity, and health and well-being, and offset the impacts of climate change; e. protecting and enhancing the special character and distinctiveness of Ipswich and helping to reinforce the attractive physical characteristics of local neighbourhoods; f. buildings that exhibit very good architectural quality, are highly sustainable and are designed for long life by being capable of adaptation to accommodate changing needs and uses over time; g. ensuring that new development incorporates cycle and waste storage, public transport infrastructure and car parking if appropriate, all designed and integrated in a way that supports the street scene and safeguards amenity; and h. new buildings in or around Air Quality Management Areas will be designed so that their size and layout will minimise, and at the very least not increase, localised retention of polluting emissions, and will include ventilation systems that protect the health of users of the buildings. Design that is considered not to adequately meet all these criteria will be refused. Policy DM8: Conservation Areas The Council will seek to protect and enhance the character and appearance of Conservation Areas through adopted Conservation Area Appraisals and Management Plans. These will be used to inform the Council's decisions when assessing the impact of proposals for planning permission. Policy DM17: Transport and Access in New Developments Each development proposal will be assessed in terms of: a. its impact on the road network in respect of traffic capacity, highway safety and the environmental impact of generated traffic; b. pedestrian and cycle accessibility to and within the site as well as the wider effects of the development upon pedestrian movement; c. its impacts on rights of way; and 98

6 d. availability of and access to public transport. Applicants will be required to demonstrate how the development would improve provision and/or how any acceptable adverse impacts would be managed and mitigated. The Council will require the inclusion of priority bus measures and dedicated cycle routes where appropriate. The Council will require mitigating measures to be provided to the satisfaction of the Highway Authority where necessary. Policy DM18: Car Parking The Council will require local parking standards to be complied with in all new development, and will expect parking to be fully integrated into the design of the scheme to provide secure and convenient facilities. Outside the IP-One area, there will be minimum parking standards for residential development and although a minimum standard is applicable, car parking must be designed so as not to dominate the development or street scene or to result in the inefficient use of land. There will be reduced, maximum, standards of provision for residential development within the IP-One Area, which has frequent and extensive public transport networks, and easy access to a wide range of employment, shopping, and other facilities. Across the Borough there will be maximum parking standards for non-residential development. A central car parking core will be defined in the town centre, through the IP-One Area Action Plan. Within the central car parking core, only operational car parking will be permitted in connection with non-residential development, so that the stock of long-stay parking is not increased. New, non-residential long-stay car parks will not be permitted. Policy DM19: Cycle Parking The Council will require minimum standards of cycle parking to be met for all new residential and major non-residential development proposals. All cycle parking is expected to be of a high quality and secure. The Council will also require the provision of secure cycle parking in any new car parks in the town. Policy DM26: Protection of Amenity Development which could lead to significant adverse effects on the amenity or environment of neighbouring uses will not be permitted. Development which could itself be significantly adversely affected by the conduct of established or potentially noisy or polluting uses nearby will not be permitted. Planning Policy Guidance Note 24 (PPG24) and BS4142 surveys will be required in relation to noise. 99

7 Exceptions will only be made where satisfactory mitigation measures can be secured through the use of planning conditions or Section 106 planning agreements. Policy DM30: The Density of Residential Development The density of new housing development in Ipswich will be as follows: a. within the town centre, Ipswich Village and Waterfront, development will be expected to achieve a high density of at least 90 dwellings per hectare (dph) (the average will be taken as 110 dph); b. within the remainder of IP-One, District Centres and an 800m area around District Centres, development will be expected to achieve a medium density of at least 40 dph (the average will be taken as 45 dph); and c. elsewhere in Ipswich, low-density development will be required (the average will be taken as 35 dph). Exceptions to this approach will only be considered where: d. the site location, characteristics, constraints or sustainable design justify a different approach; or e. a different approach is demonstrated to better meet all housing needs in the area. The National Planning Policy Framework The national planning policy framework; the replacement for the PPSs and PPGs has been material consideration when determining planning applications. Guidance is wide ranging and LPAs are required to be proactive in making planning decisions and apply a presumption in favour of sustainable development. Other key policy requirements include the need to increase the supply of new housing in well-connected locations, ensuring good standards of sustainable design* for new development that will function well, add to the overall quality of an area, optimise site potential, respond to local character and reflect the identity of local surroundings, create safe and accessible environments, and be visually attractive as a result of good architecture and appropriate landscaping. * Includes prudent use of natural resources, mitigating and adapting to climate change, and moving to a low carbon economy. 100

8 5. Comment The main issues relating to this application concern:- Principle of Development The site of the proposed development is located within St. Helens Conservation Area and within the IP-One Area boundary. It is adjacent to the Local Shopping Centre (No. 33 St. Helens Street), with 32 units. Residential development is acceptable in principle at this location, in accordance with Policy CS2 (a), subject to all other normal planning criteria. Design within Conservation Area The proposal includes some alterations to the fenestration design on Dove Street façade. The have been amended and now address the previous reason for refusal. It is considered that an additional drawing detailing the edge cladding of the retained garage gable would be useful but this could be provided for within a condition. Reason for refusal 2 of IP/13/00817/FUL is no longer considered relevant and the design proposed is in accordance with policies DM5 and DM8. Internal Layout/Density The internal layouts of the proposed one bedroom flats are proposed at c.34m², this falls significantly short (a third less floor space) of the minimum recommend standard of 51m² set out in policy DM30, para This states that especially flats, provide versatile and attractive living space that appeal to a wide audience and is therefore more sustainable in changing market conditions, the council will encourage. Having regard to the internal layout of the one-bedroom flats submitted, it would appear that circulation in bedrooms would be severely restricted and there does not appear to be space available to provide a wardrobe or other basic furniture needs. The bedroom to the rear ground floor flat would open onto the communal private amenity space and would be potentially impacted upon by noise from communal use of the area. The development would therefore represent a poor living environment and unsustainable development and is considered contrary to Policy DM 30. In addition one of the 12 core planning principles of the NPPF is to f amenity for The layout proposed does not accord with this core principle. A recent planning application refused by Ipswich Borough Council for a first floor extension to provide staff accommodation at 84 St. Helens Street, was upheld on appeal (Ref. APP/R3515/A/13/ ). The Inspectors report in considering living conditions states at paragraph 7: courages developers to meet or exceed a set of minimum floor areas. For a 1 bed 2 person dwelling this standard would be 51 square metres. The appeal The floor areas of the flats proposed in the appeal case and the current application are directly comparable and it is therefore considered that policy DM30 is of significance importance in determining this application. 101

9 In summary, the existing building does not have sufficient floor space to subdivide it into 3 adequately sized flats. The proposed one bedroom flats at 34sq.m falls significantly short of the 51sq.m standard by 17sq.m a significant amount. Environmental Health the bedroom via kitchen/living, this relates to the upper floor and having reviewed the plans it would appear feasible to address this with redesign/construction of a lobby. Private Outdoor Amenity Space A roof terrace (c.18m²), to be constructed in the roof over the garage below, is proposed to provide private outdoor amenity space for the upper floor 2 bedroom flat, this falls short of the 25m² requirement set out in Policy DM 3 but could be considered acceptable in a town centre location such as this. There is a small rear enclosed courtyard of c.9m², which is indicated as private outdoor amenity space to serve the two ground floor flats as well as a location for refuse storage for all 3 flats. As per Policy DM3, an average of 25m² should be provided per flat. The proposal would not provide an adequate area of amenity space and the space is of a poor standard, enclosed by high walls with no visual outlook or landscaping, and therefore is not considered to be in accordance with policy DM3. By designating this as an appropriate area for bin storage this further reduces the amenity of the area, particularly as each flat would have a minimum of 2 bins requiring storage for 6 wheelie bins within the confined space. An existing garage is included for the provision of cycle parking for all 3 flats. It may be possible for bin storage to be incorporated within this area, this would reduce off-road parking facilities for the site but would be preferable in this town centre location. The private outdoor amenity space provision indicated for all three flats is inadequate in size and the communal yard for the two ground floor flats represent a poor quality environment, therefore the proposed development is considered to be contrary to Policy DM 3. It is acknowledged that previous consents for two flats at the premises only provided the rear 9sq.m as amenity area and that this was considered acceptable in this location. Therefore, if there were no other objections to the development it may be that this could again be considered appropriate having balanced policy requirements with bringing the building into effective re-use. However, coupled with the need to provide bin storage for a minimum of 6 wheelie bins and the significant shortage in appropriate floorspace for 2 of the 3 residential properties now proposed, the private amenity space provision is considered to be deficient in this instance and contrary to policy DM3. Impact on Amenity The principle of conversion of the premises for residential use has already been established through planning permission Register Index no: IP/12/00817/FUL (renewal of planning permission IP/09/00806/FUL). The permission has been renewed a number of times since it was approved in 1999 under IP/99/0916/FP. The most recent permission is extant but has not yet been implemented. While there may be some impact on future residents from adjoining commercial uses, the principle has already been established for the 2 flats previously approved, and it is therefore not considered to be a significant consideration at this stage. Parking and Bin Storage 102

10 Having regard to the location within the IP-One area, there is no requirement for car parking provision on site. The submission states the garage can accommodate one car space and cycle parking for all three apartments. The parking of a car at this location would impede access to the bicycle stand indicated at the rear end of the garage and therefore should not be permitted as car parking as is not a requirement at this location. The domestic waste officer raises concern regarding the storage of bins; this would amount to up to 9 bins. The application proposes bin storage for all three apartments in the communal courtyard, this would diminish any potential for private amenity space (i.e sitting out) for residents and therefore it is considered more appropriate to provide bin storage in the garage instead, in lieu of the proposed car park space. 6.Conclusion Residential development is acceptable in principle at this central location and has been established through planning history on the site, there is a valid planning permission for change of use to 2 no. flats. The proposed development for 3 no. flats is not acceptable having regard to the limited internal floor areas which fall significantly short of the relevant standard coupled with inadequate private amenity space for residents. The floorspace of the existing building is not large enough to subdivide it into 3 adequately sized living units; the current proposal is for one appropriately sized unit and two sub-standard proposals. On balance, it is considered that increasing the density from 2 to 3 units would be over-development of the site (increasing from the approved 155 dph to 232 dph), the subdivision of the existing building into 3 rat her than 2 flats would result in inadequate internal floor areas. Inadequate internal floor areas combined with below policy requirement private outdoor amenity space would represent overdevelopment of the site and would result in a substandard and unsustainable living environment for future residents. The proposed development is considered contrary to policy DM3 and DM30 of the Core Strategy and secure high quality design and a good standard of amenity for all existing and future occupants of land and 103

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