ISLAND SITE, GREYFRIARS ROAD, IPSWICH, IP1 1UP

ISLAND SITE, GREYFRIARS ROAD, IPSWICH, IP1 1UP — Ipswich Borough Council — Appeal Decision Site visit made on 12 March 2025 by Jonathan Price BA(Hons) DipTP DMS MRTPI an Inspector appointed by the Secretary of State Decision date: 24 March 2025 Appeal Ref: APP/R3515/W/24/3351262 Island Site, Greyfriars Road, Ipswich IP1 1UP • The appeal is made under section 78 of the Town and Country Planning Act 1990 (as amended) against a refusal to grant planning permission. • The appeal is made by Mr Ian Bullough against the decision of Ipswich Borough Council. • The application Ref is IP/24/00035/FUL. • The development proposed is automated carwash with six EV charging points, associated substation and meter cupboards for substation. Decision 1. The appeal is allowed and planning permission is granted for an automated carwash with six EV charging points, associated substation and meter cupboards for substation at Island Site, Greyfriars Road, Ipswich IP1 1UP in accordance with the terms of the application, Ref IP/24/00035/FUL, subject to the conditions set out in the Schedule attached to this decision. Preliminary Matters 2. The appeal submission included five documents1 not part of the original planning application.

ISLAND SITE, GREYFRIARS ROAD, IPSWICH, IP1 1UP — Ipswich Borough Council — Appeal Decision These provide a Preliminary Ecological Appraisal (PEA), Biodiversity Net Gain (BNG) Assessment, Heritage Technical Note (HTN), Landscape Layout and Detailed Planting Plan (LLDPP) and perspective sketches of the proposal. None of these evolve the scheme but all inform an assessment of the proposal against the Council’s reasons for refusal. The Council will have had the opportunity to consider this further information in producing its own statement of case. No third parties made representations to either the planning application or appeal, so there would be no procedural unfairness in taking this further information into account as part of the appellant’s case. Main Issues 3. The effects of the proposal on • biodiversity, and • the character and appearance of the area. 1 Preliminary Ecological Appraisal by ArbTech, August 2024. Biodiversity Net Gain Assessment by ArbTech, August 2024. Heritage Technical Note by Cotswold Archaeology, July 2024. Landscape Layout and Detailed Planting Plan by Nicola Jayne Landscape Design, July 2024. Indicative Sketches by PR Architects, September 2024. https://www.gov.uk/planning-inspectorate

ISLAND SITE, GREYFRIARS ROAD, IPSWICH, IP1 1UP — Ipswich Borough Council — Appeal Decision Appeal Decision APP/R3515/W/24/3351262 Reasons Biodiversity 4. The proposed car wash relates to a vacant and overgrown ‘island’ site in Ipswich town centre, created by the re-routing of Greyfriars Road to the north and the establishment of the roundabout to the east. The oblong site comprises 669 square metres and is contained by roads forming part of a complex highway arrangement within the town’s inner ring road. Surrounding uses include a four-storey hotel to the north beyond Greyfriars Road, a builder’s merchants to the west and a retail park to the south. Amongst the large-scale blocks of recent town centre development, there are extensive areas of car parking. Various maintained grassed areas exist in the vicinity which are not joined up and appear incidental to road and development arrangements. There are sections of tree planting forming the landscaping within and around this development. There is little by way of natural habitat and the small green pockets provide little species connectivity within this highly urbanised and car dominated context. 5.

ISLAND SITE, GREYFRIARS ROAD, IPSWICH, IP1 1UP — Ipswich Borough Council — Appeal Decision The Council’s first reason for refusal is over the lack of an ecological appraisal of the biodiversity value the site has accrued having remained undeveloped for a long period. This rested on conflict with Policy DM8 of the Ipswich Local Plan2. This states that all development must incorporate measures to provide BNG and that proposals which would result in significant harm or net loss to biodiversity, having appropriate regard to the 'mitigation hierarchy', will not normally be permitted. 6. The PEA found the appeal site to consist of unmanaged grassland, scattered trees and self-set saplings, mainly sycamore. It was noted that due to its lack of management, scrub had encroached in places and the metallic boundary fencing around the land was partly broken. Due to a lack of regular management and maintenance, the grassland boasted moderate levels of structural and species diversity, and more than six species were present per square metre. The grassland was found to present good opportunities for microclimates to form, but the low value of the existing habitat was not likely to have a significant impact on local invertebrate populations. 7. There were no buildings or trees suitable for roosting bats.

ISLAND SITE, GREYFRIARS ROAD, IPSWICH, IP1 1UP — Ipswich Borough Council — Appeal Decision The foraging value of the site for these protected species was found to be limited due to the absence of linear features connecting to the wider landscape. The site was not found suitable habitat for schedule 1 birds but could provide nesting opportunities for commoner species. The PEA therefore recommended vegetation removal be undertaken outside the bird nesting period of 1st March to 31st August. 8. The highly urbanised nature of the site meant it was not suitable habitat for protected species such as badgers or dormice. Hedgehogs might use it, but the loss of such habitat was found inconsequential to local populations, owing to their low value and the presence of more extensive habitat locally. Notwithstanding the very limited biodiversity value identified, the extent of building and hard surfacing of the site was anticipated to result in a net loss. 9. In my view, the PEA addresses the lack of a biodiversity appraisal. On the basis of this, I find the biodiversity value of the site to be demonstrated as being very low. 2 This comprises the Core Strategy and Policies Development Plan Document Review (2022) https://www.gov.uk/planning-inspectorate 2

ISLAND SITE, GREYFRIARS ROAD, IPSWICH, IP1 1UP — Ipswich Borough Council — Appeal Decision Appeal Decision APP/R3515/W/24/3351262 The Council has provided no specialist ecological evidence of its own that would dispute this. 10. The BNG assessment notes that the application was submitted prior to the mandatory requirement to achieve 10% net gain. Nevertheless, LP Policy DM8 states all development must incorporate measures to provide net gains for biodiversity. Using the statutory metric, the BNG assessment applied a lower target of 1% and found that the scheme could not achieve this. As the proposal would result in a net loss of biodiversity, there would be conflict with LP Policy DM8. Based on the BNG assessment, the appellant suggests a pre-commencement planning condition to secure a net gain through an off-site financial contribution. 11. The proposal would result in a small net loss of biodiversity on a site with low value in this regard. The conflict with LP Policy DM8 would result in a very low degree of biodiversity harm. Character and appearance 12. Policy DM12 of the LP requires all new development to be well designed. The appeal site is located within Ipswich Town Centre but is not allocated for a specific use. It is surrounded by the main highway network and large-scale commercial uses.

ISLAND SITE, GREYFRIARS ROAD, IPSWICH, IP1 1UP — Ipswich Borough Council — Appeal Decision This is a highly urbanised, car-dominated and very active commercial zone, where a car wash facility would add a further well-related and appropriate service. As a use, I agree with the appellant that this would be in keeping with its immediate surroundings and provide benefits through the delivery of new and appropriate modern facilities, including electric vehicle charging points, to serve this trafficked route in an urban and commercial area of Ipswich. 13. The car wash building would be predominantly constructed using shale grey wall panels, with the north elevation glazed with anthracite aluminium window frames. The mono-pitched green roof would be viewed as part of this main road fronting elevation. In the context of a mainly contemporary urban townscape that frames the site, the functional appearance of the building would be appropriate and provide a suitable mix of materials and colours. 14. The Council considers a three to four storey building to be most appropriate in this location. Such a major redevelopment proposal might arise in the future.

ISLAND SITE, GREYFRIARS ROAD, IPSWICH, IP1 1UP — Ipswich Borough Council — Appeal Decision However, as a suitable use in this location, a smaller scale and height of building providing an automated car wash with associated EV charging facilities, would be fitting. This smaller, functional facility would be appropriately subservient in scale and appearance to the surrounding and more visually dominant architecture. 15. The island site occupies a prominent position, adjacent to major roads and a high volume of passing traffic. A low profile, utilitarian structure, with a green roof and the screening of trees, hedging and other planting, would minimise visual intrusion and avoid taking the eye away from the more prominent buildings in the vicinity. I disagree that the appropriate redevelopment of this site requires the same degree of architectural articulation or extent of landscaping displayed by the much larger- scale developments nearby. That the car wash development would be underwhelming in scale is entirely appropriate for a use of this nature and its prominent location. 16. The built scheme would occupy a large proportion of the site but still leave space for some judicious landscaping. As shown on the LLDPP, the scheme would retain https://www.gov.uk/planning-inspectorate 3

ISLAND SITE, GREYFRIARS ROAD, IPSWICH, IP1 1UP — Ipswich Borough Council — Appeal Decision Appeal Decision APP/R3515/W/24/3351262 two small trees and replace the current unmanaged and self-seeded vegetation with six new trees, a new native hedgerow, a small wildflower meadow, and further shrubs and herbaceous plants. The tree planting would be focused on each end of the car wash structure, where vehicles enter and leave, screening the visually more open, active parts of the scheme. 17. The appearance of the longer, outwardly facing side of the building would be softened by hedging. Such hedging would of course need to be maintained, both to access the building’s exterior and prevent obstruction of the adjacent footway. The Council contests the feasibility of establishing planting along the outer edge of the development, due to the narrowness of the gap and its northern aspect. However, I have no horticultural evidence to show suitable hedging could not be provided and maintained along this edge of the building to enhance the scheme’s appearance. Were the main northern elevation of the building likely to be prone to mould, then addressing this might be incorporated into wider landscaping maintenance that might be conditional upon scheme approval. 18.

ISLAND SITE, GREYFRIARS ROAD, IPSWICH, IP1 1UP — Ipswich Borough Council — Appeal Decision The functional and contemporary design, softened by adequate landscaping, would complement the active commercial surroundings and suitably reflect the character and appearance of this part of the town centre. As such, and by improving the current poor-quality appearance of the site, this proposal meets the relevant design and character requirements of LP Policy DM12. Other Matters 19. The Council’s appeal statement draws my attention to the comments of its Conservation and Design Officer. Although not adopted as part of the refusal reasons, these comments referred to the proposal harming the setting of the Grade II* Listed Church of St Peter within the Ipswich Central Conservation Area (CCA). The part of Policy DM12 referred to in the refusal reason, requiring proposals to respect and promote special character and distinctiveness by ensuring good architectural design that responds to and reflects its setting, would relate to these concerns. 20. Cognisant of these, the appellant produced a HTN with the appeal, prepared by a suitably qualified consultant with background knowledge of the area, its planning history and the designated heritage asset concerned.

ISLAND SITE, GREYFRIARS ROAD, IPSWICH, IP1 1UP — Ipswich Borough Council — Appeal Decision The appeal site is separated from the CCA by the intervening roundabout to its east, and St Peter’s Church is clearly seen across this, to the other side. The significance of both heritage assets is described in the HTN. The appeal site is accurately assessed as forming part of a modern cityscape characterised by mixed grain urban form, including the Novotel Hotel, Cardinal Park and other large scale commercial uses, highway infrastructure, including signage and lighting, as well as traffic with its associated noise and movement. The HTN concludes that this modern urban development to the west of St Peter’s church and the CCA does not contribute to their significance as designated heritage assets but detracts from their appreciation. The appeal scheme would comprise a subservient addition to this modern cityscape, neither contributing to nor causing harm to the significance of the two designated heritage assets to the east. 21. I concur with the findings of the HTN that the proposal would be in keeping with the existing urban context and as such be of no harm to the significance of either St Peter’s Church or the CCA, as a result of change within their settings. Therefore, https://www.gov.uk/planning-inspectorate 4

ISLAND SITE, GREYFRIARS ROAD, IPSWICH, IP1 1UP — Ipswich Borough Council — Appeal Decision Appeal Decision APP/R3515/W/24/3351262 the proposal is consistent with Section 66(1) of the Planning (Listed Buildings and Conservation Areas) Act 1990 and complies with LP Policy DM13. Planning balance 22. The proposal would bring about an appropriate redevelopment of a long-vacant site in the town centre. The improvement to the current appearance of the site and the economic activity generated would be beneficial in the context of this vibrant, commercial sector. The scheme would comprise an appropriate use in this location, be of suitable design and provide adequate landscaping. It would be acceptable in respect of both character and appearance and heritage considerations. The lack of feasible on-site BNG would be a low level of harm. The wider environmental and economic benefits would outweigh this and not prevent an overall finding that the proposal would comply with the development plan considered as a whole. Conditions and conclusion 23. I have looked at the conditions suggested by the Council in framing those necessary and meeting the further required tests.

ISLAND SITE, GREYFRIARS ROAD, IPSWICH, IP1 1UP — Ipswich Borough Council — Appeal Decision In addition to applying the standard time limit for commencement and plan compliance, further conditions are necessary to secure the required access arrangements, on-site parking, manoeuvring space and landscaping implementation. Subject to these I conclude the appeal should be allowed.

ISLAND SITE, GREYFRIARS ROAD, IPSWICH, IP1 1UP — Ipswich Borough Council — Jonathan Price INSPECTOR Schedule of Conditions 1) The development hereby permitted shall begin not later than three years from the date of this decision. 2) The development hereby permitted shall be carried out in accordance with drawing nos. ref: 2228-P.01 (location plan), 2228-P.03B (proposed site plan), 2228-P.04A (proposed elevations), 2228-P.05 (EV parking details) and 0285- LA-01 revP2 (LLDPP). 3) Prior to the commencement of the development hereby permitted, details of the new highway access shall have been submitted to and approved in writing by the local planning authority. These details shall include: o means to prevent the discharge of surface water from the development onto the highway, including any system to dispose of the water o accordance with Suffolk County Council Standard Access Drawing no.

ISLAND SITE, GREYFRIARS ROAD, IPSWICH, IP1 1UP — Ipswich Borough Council — Jonathan Price DM03 with an entrance width of 4.5 metres o The gradient of the vehicular access to be no steeper than 1 in 20 for the first five metres measured from the nearside edge of the highway o the visibility splays as shown on drawing no.2228-P.03B maintained with no obstruction to visibility over 0.6 metres high o bound material for a minimum distance of 5 metres measured from the nearside edge of the metalled carriageway https://www.gov.uk/planning-inspectorate 5

ISLAND SITE, GREYFRIARS ROAD, IPSWICH, IP1 1UP — Ipswich Borough Council — Jonathan Price DM03 with an entrance width of 4.5 metres o The gradient of the vehicular access to be no steeper than 1 in 20 for the first five metres measured from the nearside edge of the highway o the visibility splays as shown on drawing no.2228-P.03B maintained with no obstruction to visibility over 0.6 metres high o bound material for a minimum distance of 5 metres measured from the nearside edge of the metalled carriageway https://www.gov.uk/planning-inspectorate 5 Appeal Decision APP/R3515/W/24/3351262 The development shall thereafter accord with the approved details. 4) Prior to the bringing into use of the development hereby permitted, an implementation and maintenance plan for the approved LLDPP shall be submitted to and approved in writing by the local planning authority. The completed scheme shall be implemented and thereafter maintained in accordance with the approved details. 5) Prior to the bringing into use of the development hereby permitted, the areas within the site shown on drawing no. 2228 P.03B for the purposes of manoeuvring and parking of vehicles as well as the charging of electric vehicles shall be provided and thereafter retained and used for no other purposes. ---- https://www.gov.uk/planning-inspectorate 6