3.9 Network Rail (Ipswich Chord) Order - Planning Statement

INFRASTRUCTURE PLANNING

THE INFRASTRUCTURE PLANNING (APPLICATIONS: PRESCRIBED FORMS AND PROCEDURE)

REGULATIONS 2009

NETWORK RAIL (IPSWICH CHORD) ORDER

______________________________________________

PLANNING STATEMENT ______________________________________________

Regulation number:

Regulation 5(2)(q)

Document Ref: 3.9 Author

Network Rail

Date: 6th June 2011 Date of revision & version number:

6th June 2011 Rev 2.0 14th April 2011 Rev 1.1 18th March 2011 Rev 1.0

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Planning Statement Doc Ref: 3.9

TABLE OF CONTENTS

1 INTRODUCTION, SCOPE & PURPOSE 3-9 2 SUMMARY 10-11 3 DESCRIPTION OF DEVELOPMENT 12-13 4 SITE AND SURROUNDINGS 14 5 RELEVENT PLANNING HISTORY OF SITE &

SURROUNDINGS 15-16

6 RELEVENT NATIONAL POLICIES 17-19 7 DEVELOPMENT PLAN POLICIES 20-22 8 ANALYSIS 23-27 9 CONDITIONS 28-29 10 CONCLUSIONS 30

Appendix 1: A plan showing the relationship of the access road and three sites together with the four PCCL planning permissions

31-63

GLOSSARY 64

BIBLIOGRAPHY 65-66

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1 Introduction, Scope & Purpose Introduction 1.1 This Planning Statement (this Statement) relates to an application (the

Application) made by Network Rail Infrastructure Limited (Network Rail) to the Infrastructure Planning Commission (IPC) under the Planning Act 2008 (PA2008) for the Network Rail (Ipswich Chord) Order (the DCO) which would grant powers to construct and maintain a new railway chord (the Ipswich Chord Development).

1.2 This Statement has been prepared for compliance with the

requirements of Regulation 5(2)(q) of the Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009. In the absence of a National Networks National Policy Statement (NNNPS) and taking into account the IPC ‘Advice note one: Local Impact Reports’ this Statement sets out the planning policy context at national, regional and local level. It sets out how the Ipswich Chord development relates to those policies and impacts on other developments in the area through which the Chord passes.

1.3 This Statement forms part of a suite of Application documents and

should be read alongside and is informed by those documents. 1.4 Network Rail Infrastructure Limited intends to construct the Ipswich

Chord Development, a 1.415 km chord to link the Great Eastern Main Line with the East Suffolk Line to the north of Ipswich, Suffolk.

1.5 The proposed development is the construction of the railway (Work No.

1) and the other works detailed below, as set out in Part 1 of Schedule A to the DCO.

In the county of Suffolk, districts of Ipswich and Babergh

1.5.1 Work No. 1 – A railway 1,415 metres in length, commencing at a

point on the existing Great Eastern Main Line railway 650 metres north-west of the bridge carrying that railway over Sproughton Road, passing south-eastwards on existing embankment then passing south-eastwards over the River Gipping, curving eastwards and then north-eastwards on the south-eastern side of the River Gipping then joining the existing East Suffolk Line railway passing back over the River Gipping and terminating at a point on the East Suffolk Line railway 70 metres north-east of the bridge carrying that railway over the river.

1.5.2 Work No. 1 includes widening of the existing embankment

carrying the Great Eastern Main Line railway on its north-eastern side supported by a retaining wall; a new bridge adjacent to the existing bridge carrying the Great Eastern Main Line railway over Sproughton Road; a bridge over the River

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Gipping; an embankment carrying the proposed railway on the south-eastern side of the River Gipping; and the reconstruction of bridge 404 carrying the East Suffolk Line railway over the River Gipping.

Associated development comprising:

1.5.3 Work No. 2 – Diversion of a surface water sewer commencing at

a point 75 metres south of the junction of Sproughton Road and Boss Hall Road, passing south-eastwards and terminating by means of an outfall into the River Gipping at a point 55 metres north-east of the bridge carrying the Great Eastern Main Line railway over the river;

1.5.4 Work No. 3 – Extension of the training wall on the southern side

of the River Gipping between points R1 and R2 on the works plans;

1.5.5 Work No. 4 – An access road commencing at a point 205

metres south of the bridge carrying the East Suffolk Line railway over the River Gipping passing north-eastwards through the proposed embankment (Work No. 1) by means of an underpass, then passing south-westwards by means of a ramp and terminating at a point on the said embankment 110 metres south-west of the point of commencement;

1.6 In connection with these works the DCO would authorise further

associated development within Order limits consisting of:

1.6.1 demolition of the former cold store building at the Harris Factory site;

1.6.2 electrical equipment and signalling works;

1.6.3 ramps, means of access and footpaths;

1.6.4 embankments, aprons, abutments, retaining walls, wing walls

and culverts;

1.6.5 works to alter the position of apparatus, including mains, sewers, drains and cables; and

1.6.6 works to alter the course of, or otherwise interfere with, a

watercourse other than a navigable watercourse;

1.6.7 landscaping and other works to mitigate any adverse effects of the construction, maintenance or operation of the authorised project;

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1.6.8 works for the benefit or protection of land affected by the authorised project;

1.6.9 working sites in connection with the construction of the authorised project; and

1.6.10 such other works as may be necessary or expedient for the purposes of or in connection with the construction of the authorised project provided that they are within the scope of the ES.

1.7 The development described above would be subject to specific

requirements regarding the approved plans, landscaping, highway accesses, archaeology, construction methodology and other matters set out in Part 2 of Schedule A to the DCO.

Scope & Purpose

1.8 In accordance with Section 104(2) of the PA2008 an application for a DCO must be determined by the Panel or Council having regard to:-

(a) any national policy statement which has effect in

relation to the development of the description to which the application relates (a “relevant national policy statement”),

(b) any local impact report (within the meaning given by

section 60(3)) submitted to the Commission before the deadline specified in a notice under section 60(2),

(c) any matters prescribed in relation to development of

the description to which the application relates, and (d) any other matters which the Panel or Council thinks

are both important and relevant to its decision. 1.9 The importance of the national policy statement (NPS) in determining

an application for a DCO is further referred to in Section 104(3) of the PA2008. An application for a DCO must be determined by the Panel or Council:-

“…in accordance with any relevant National Policy Statement (NPS) except to the extent that one or more of subsections (4) to (8) apply.”

1.10 Where there is no approved NPS in place the DCO is determined by

the Secretary of State as set out in Section 105 of the PA2008 as follows:-

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“(1) This section applies in relation to an application for an order granting development consent if the decision-maker is the Secretary of State. (2) In deciding the application the Secretary of State must have regard to—

(a) any local impact report (within the meaning given by section 60(3)) submitted to the Commission before the deadline specified in a notice under section 60(2), (b) any matters prescribed in relation to development of the description to which the application relates, and (c) any other matters which the Secretary of State thinks are both important and relevant to the Secretary of State's decision.”

1.11 At the time of preparation of this statement no NPS has been approved

for National Networks nor has a draft been published for consultation. In the absence of a National Policy Statement on National Networks the purpose of this document is to set out National, Regional and Local planning policies, both in the Development Plan and other planning policy guidance and advice, relevant to the construction of the proposed Ipswich Chord and to explain how the proposed Ipswich Chord accords with those policies and advice. In particular whilst not a test specifically referred to in the PA2008 the proposed development is considered in light of the test applied to the determination of planning applications under the Town & Country Planning Act 1990 (as amended by the Planning and Compulsory Purchase Act 2004)

“If regard is to be had to the development plan for the purpose of any determination to be made under the Planning Acts the determination must be made in accordance with the plan unless material considerations indicate otherwise”. (S38(6) Planning and Compulsory Purchase Act 2004)

1.12 In December 2010 the Department of Communities and Local

Government (DCLG) published “Major Infrastructure Planning Reform, Work Plan” (MIPRWP), which sets out the changes to the consideration and determination of DCOs as set out in the Localism Bill (LB) published on the 13 December 2010. The LB abolishes the Infrastructure Planning Commission and transfers its functions to the Major Infrastructure Planning Unit of the Planning Inspectorate. Whether or not there is an approved NPS in place the proposal in the LB is that all decisions will be made by the Secretary of State.

1.13 The MIPRWP sets out at paragraph 19 how it is proposed that DCOs

will be determined:-

“The relevant Secretary of State will determine applications for development consent in accordance with designated national policy statements, following consideration of the

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report and recommendation from the Major Infrastructure Planning Unit. In the absence of a national policy statement, decisions will be based on established policy, the Major Infrastructure Planning Unit’s recommendation and other matters the Secretary of State deems to be both important and relevant.”

1.14 Paragraphs 26 to 31 of MIPRWP deals with the timetable for the

production of the various NPS’s. In a box at the end of this section in relation to an NPS for transport it states

“The Department for Transport will announce the timetable for transport National Policy Statements, in early 2011.”

1.15 On the 24 March 2011 the government published, ‘The Plan for

Growth’. At paragraph 2.33 details of the timetable for the production of a number of the proposed National Policy Statements is given. This includes the National Networks NPS which is due to be published for consultation purposes in December 2011 and laid for approval and designated by Dec 2012.

1.16 Section 60 of the PA 2008 requires the Commission to invite relevant

local authorities to submit a:-

“local impact report giving details of the likely impact of the proposed development on the authority’s area”

1.17 The Infrastructure Planning Commission has issued ‘Advice note one:

Local Impact Reports’ in March 2010. It acknowledges that what is included in a Local Impact Report is a matter for the local authority concerned. It does then set out a list of topics which may be of assistance to a local authority in determining what to include as follows:-

• Site description and surroundings/location • Details of the proposal • Relevant planning history and any issues arising • Relevant development plan policies, supplementary planning

guidance or documents, development briefs or approved master-plans and an appraisal of their relationship and relevance to the proposals

• Relevant development proposals under consideration or granted permission but not commenced or completed

• Local area characteristics such as urban and landscape qualities and nature conservation sites

• Local transport patterns and issues • Site and area constraints • Designated sites • Socio-economic and community matters

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• Consideration of the impact of the proposed provisions and requirements within the draft Order (such as the scheme) in respect of all the above

• Development consent obligations and their impact on the local authority’s area

The LB does not propose any amendments to Section 60 of the PA2008.

1.18 The topics listed above are in the main addressed in the Environmental Statement (ES) (Application Documents 4.1-4.4) submitted with the Application. However the second, third and fourth bullet points above referring to relevant planning history, development plan policies and other policy advice and other relevant development proposals are not analysed as a distinct section in the ES.

1.19 The Assessment of Need (Application Document 6.3) sets out the

strategic transport case for the Ipswich Chord (IC) as developed from the Government’s policy for the railways. This was set out in ‘Delivering a Sustainable Railway’ DfT July 2007, in particular Appendix A the ‘High Level Output Statement’ which detailed the outputs the government were seeking during CP4. This high level output requirement is translated into physical requirements through the RUS which NR produce as part of its licence requirements, having determined what is needed to deliver the governments policy for the railways.

1.20 The timetable for the production of the National Networks NPS (see

paragraph 1.16 above) means that if IPC process for determining the DCO application is to be met the draft National Networks NPS may be published approximately half way through the formal consideration of the DCO. It is unlikely that the National Networks NPS will be approved before a decision is due on the DCO. This being the case existing National and Regional Planning Policy will be an important consideration in determining whether the proposed development accords with planning policy or not.

1.21 In the absence of a transport NPS the national policy framework set out

in the Assessment of Need sets the context in which the Ipswich Chord is being promoted and clearly establishes the transport case for it. This Planning Statement starts from the premise that the transport case is as made out in the Assessment of Need and relates that to planning policy.

1.22 Section 3 of this statement is a description of the development, section

4 gives a description of the site and its setting, section 5 sets out relevant planning history of site and surroundings, section 6 sets out relevant national planning policy and guidance, section 7 Development Plan Policies, section 8 analyses the proposed development against the policies set out in sections 6 and 7 and considers the relevance of

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the history of development in the area and current proposals, section 9 is a commentary on the proposed conditions set out in Part 2 of Schedule A to the DCO and section 10 is a conclusion.

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2 Summary 2.1 The determination of this DCO must be made in accordance with the

NPS on National Networks and any local impact report prepared by a local authority (paragraph 1.8).

2.2 Where there is no approved NPS the determination must be in

accordance with the local impact report and any matters considered important and relevant to the Secretary of State’s decision (paragraph 1.10)

2.3 Changes proposed in the Localism Bill require decision to be made in

accordance with the relevant NPS and in its absence will be based on established policy (paragraph 1.13)

2.4 The National Networks NPS may be published in draft but is unlikely to

approved before a decision is due on this application (paragraph 1.20) 2.5 In the absence of an NPS the transport case is as set out in the

Assessment of Need and this Planning Statement sets out the planning policy context (paragraph 1.21)

2.6 The area referred to as the Harris factory site is the subject of a

number of unimplemented planning permissions which will be impacted either directly or indirectly by the proposed authorised works. Details of those planning consents are given in paragraphs 5.2 - 5.8.

2.7 An area of land at Europa Way has an unimplemented planning

consent which will be affected by the proposed authorised development. Details of this consent are given at paragraph 5.9.

2.8 National policy emphasises the importance of sustainable development

(paragraph 6.5). The importance of key international gateways and national transport corridors in delivering a sustainable transport system is set out at paragraphs 6.7 - 6.11.

2.9 The weight to be given to the Regional Spatial Strategies (RSS) in the

light of their intended abolition is set out in paragraph 7.2 and 7.3. In the absence of a National Networks NPS it is concluded that considerable weight must be given to RSS policies as the proposal whilst having a mainly local impact is important to the regional and national strategic freight network.

2.10 The adopted Ipswich Local plan (November 1997) – Saved Local Plan

Policies is now fourteen years old (paragraph 7.5) and contains no specific reference to the Ipswich Chord.

2.11 The Ipswich Local Plan First Deposit Draft, November 2001 did contain

a specific policy supporting the principle of the Ipswich Chord. The plan

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was never adopted because of the changes brought about by the Planning and Compulsory Purchase Act 2004 (paragraph 7.9).

2.12 The Ipswich Core Strategy and Policies Development Plan Document

submitted to the Secretary of State in March 2010 also contains a specific policy supporting the Ipswich Chord (paragraph 7.10).

2.13 The key function the Felixstowe to Nuneaton railway plays in the

Strategic Rail Freight Network (SFN) is analysed in paragraphs 8.1 - 8.5 and its fit with the transport policies of the RSS.

2.14 The support given by the emerging local plan from Ipswich Borough

Council is set out in paragraphs 8.7 – 8.11. At paragraph 8.12 it is considered that more weight should be given to the emerging local plan than to the adopted local plan given the age of the adopted plan.

2.15 The impact of the Ipswich Chord on two key development sites, the

Harris factory site and site at Europa Way is examined in paragraphs 8.14 – 8.19. In both cases the conclusion is that whilst there is some permanent loss of land which means one of the three planning permissions on the Harris Factory site and the planning permission on Europa Way cannot be implemented it would nevertheless leave both sites capable of development.

2.16 Paragraph 8.20 notes a marginal loss of existing active employment

land but paragraph 8.21 concludes that the permanent loss of existing and future employment land is marginal and does not outweigh the benefits of the Ipswich Chord.

2.17 The impact of the Ipswich Chord on the River Gipping riverside cycle

path footpath is considered at paragraph 8.22. 2.18 The reasoning and purpose of the requirements set out in Schedule A

part 2 of the DCO are examined in section 9.

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3 Description of Development 3.1 The broad details of the authorised works are set out in Paragraphs 1.5

to 1.7 above. The main works are set out in paragraph 1.5 3.2 The new chord leaves the Great Eastern Main Line (GEML) at a

junction at the northern end of Europa Way. Between there and Sproughton Road the existing railway embankment is widened on the east side to effectively create a four track railway, the two existing tracks of the GEML and the two new tracks of the Ipswich Chord.

3.3 Sproughton Road is crossed by a new bridge running parallel to the

existing rail bridge. The structure of the new bridge is such that the future aspirations of Ipswich Borough and Suffolk County Councils to provide a full width footpath/cycleway on the north side of Sproughton Road can be accommodated. The design of the bridge reflects the simple functional design of the existing bridge.

3.4 South of Sproughton Road the two new lines of the Ipswich Chord

continue parallel to the existing two lines of the GEML. However between Sproughton Road and the River Gipping the new lines will be supported by a concrete retaining wall. There is a relatively narrow corridor of land between the existing railway and the buildings which form part of the Boss Hall Estate. This narrow corridor also needs to accommodate the Anglian Water surface water sewer. There is therefore insufficient room for the existing earth embankment to be widened. It is therefore necessary to build a concrete retaining wall. There will be limited views of this wall which will be seen through the gaps between buildings in the Boss Hall Estate.

3.5 Just north of the River Gipping the new railway starts to curve away

towards the east crossing the River Gipping on a new bridge. The span of the bridge is sufficient to cross both the river and provide for the existing cycle/footpath on the north side of the river to be retained.

3.6 The railway then curves round to the north-east until it meets the East

Suffolk Line (ESL) just where it crosses the River Gipping. Between the two river crossings the railway is carried on an earth embankment on a rising gradient as the ESL is at a higher elevation than the GEML.

3.7 Towards the ESL an underbridge is provided through the embankment

primarily to provide access for maintenance purposes to the railway with a ramped access to rail level being provided on the north side of the embankment. This bridge will also provide access to the river for the Environment Agency, a route for the future cycle/footpath and access to the land between the river and railway.

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3.8 The existing bridge over the River Gipping which currently carries the ESL will need to be widened slightly to accommodate the start of the new railway junction. Additionally, the existing bridge is reaching the end of its useful life and would have required replacement in the foreseeable future. The new bridge makes provision for the existing footpath/cycleway that runs along the north bank of the River Gipping.

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4 Site and Surroundings 4.1 A full description of the site and its surroundings is given in the, ES

(Application Document 4.1) Section 1.4 Chapter 8 Vol. 3. The main character of the area through which the Ipswich Chord will pass is of an industrial nature and one major brownfield site, the former Harris Meat factory. The character of the area is further defined by the two existing railways the GEML and ESL which the Ipswich Chord will connect. Both of these railway lines are on embankments as the railways cross the valley and flood plain of the River Gipping.

4.2 The River Gipping is the major topographical feature of the area and will be crossed twice by the Ipswich Chord, on a new bridge immediately to the east of the existing rail bridge which carries the GEML over the River Gipping and on the reconstructed bridge (bridge 404) which carries the ESL over the River Gipping.

4.3 As indicated above the area through which the Ipswich Chord passes is industrial/commercial in character. There are however a terrace of five residential properties next to the Sproughton Road railway bridge with the new Chord passing between the existing GEML and the end of the terrace.

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5 Relevant Planning History of site and surroundings 5.1 The former Harris Meat Factory site which lies between the Great

Eastern and East Suffolk railway lines south of the River Gipping has had a number of recent planning consents for industrial/commercial development.

5.2 In 2004 a full planning application for “proposed new Public transport

workshop and offices, external aprons, roadways, parking and landscaping”, on part of the site was approved by Ipswich Borough Council on the 23 April 2004 (Ipswich Borough Council ref 04/00096/FUL). This consent was not implemented and has now lapsed.

5.3 In 2004 an outline planning application for “layout of industrial estate

for bus depot, concrete batching site, waste disposal site, concrete re-cycling and Enterprise units (B1, B2, B8) and alterations to vehicular access””, on the whole site was approved by Ipswich Borough Council on the 4 May 2004 (Ipswich Borough Council ref 04/00115/OUT). This consent was not implemented and has now lapsed.

5.4 In 2008 a full planning application for “Construction of access road and

associated infrastructure including lighting and railway containment barriers”, on the entrance to the site from Hadleigh Road was approved by Ipswich Borough Council on the 6 November 2008 (Ipswich Borough Council ref 08/00696/FUL). This consent was not yet been implemented and remains valid until the 5 November 2011.

5.5 In 2008 a full planning application for “Erection of one B2/B8

commercial unit with associated external works (Plot 2)”, at the southern end of the site adjacent to Plot 1 (see below) was approved by Ipswich Borough Council on the 5 March 2009 (Ipswich Borough Council ref 08/00928/FUL). This consent has not yet been implemented and remains valid until the 4 March 2012.

5.6 In 2008 a full planning application for “Erection of two terraces of six

and four single storey Class B1/B2 commercial units with associated external works (Plot 1)”, at the southern end of the site adjacent the Hadleigh Road access was approved by Ipswich Borough Council on the 5 March 2009 (Ipswich Borough Council ref 08/00929/FUL). This consent has not yet been implemented and remains valid until the 4 March 2012.

5.7 In 2008 a full planning application for “Refurbishment of former cold

store building to create nine commercial units for B1, B2, and B8 use, with associated elevation; alterations and external works (Plot 3)”, was approved by Ipswich Borough Council on the 5 March 2009 (Ipswich Borough Council ref 08/00970/FUL). The cold store is the only remaining building on the site close to the River Gipping. This consent

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has not yet been implemented and remains valid until the 4 March 2012.

5.8 The four planning permissions and a plan showing the relationship of

the access road and three sites are attached as Appendix 1. 5.9 The land immediately to the north of Sproughton Road lying between

the GEML and Europa Way currently has a valid planning consent for “Erection of food store totalling 1796m2 and associated car parking up to 14 convenience units comprising of A1, A2, B1, A3-5, D1 and D2 totalling 3194m2, 110 flats, 32 retirement dwellings, decked car parking space and surface car park, roof gardens (up to 6 storeys high) ancillary hard and soft landscaping and construction of vehicular accesses”. This was granted by Ipswich Council on the 14 July 2006 (Ipswich Borough Council ref 05/00599/FUL). This consent has not yet been implemented and remains valid until the 13 July 2011.

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6 Relevant National Policies PPS 1 Delivering Sustainable Development 6.1 The Government’s general approach to planning policy is set out in

PPS 1 Delivering Sustainable Development. The four aims of sustainable development are set out at paragraph 4:

social progress that recognises the needs of everyone effective protection of the environment the prudent use of natural resources and the maintenance of high and stable levels of economic growth and employment

6.2 The general approach is set out at paragraph 27 and includes, at (iv)

the need to take account of accessibility and sustainable transport needs and, at (vii), to encourage accessible public transport to secure more sustainable patterns of transport development.

Planning and Climate Change Supplement to PPS 1 6.3 Subsequent to the publication of PPS 1 a supplement was published

on ‘Planning and Climate Change’ in December 2007. The government considers that:

“Addressing climate change is therefore the Government’s principal concern for sustainable development.”

6.4 The key planning objectives by which a full and appropriate response to climate change is to be delivered is set out at paragraph 9 with the third point being:

“– deliver patterns of urban growth and sustainable rural developments that help secure the fullest possible use of sustainable transport for moving freight, public transport, cycling and walking; and, which overall, reduce the need to travel, especially by car”

PPG 13 Transport 6.5 Government policy on transport is set out in PPG13 issued in March

2001. The objectives of the policy are set out at paragraph 4:-

promote more sustainable transport choices for both people and for moving freight promote accessibility to jobs, shopping, leisure facilities and services by public transport, walking and cycling, and reduce the need to travel, especially by car.

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6.6 The general advice to local planning authorities is then listed in a number of ‘bullet points’ at paragraph 6 including:-

Protect sites and routes which could be critical in developing infrastructure to widen transport choices for both passenger and freight movements

Delivering a Sustainable Transport System (DfT, Nov 2008) 6.7 This document sets out the Government’s response to The Eddington

Transport Study and the Stern Review. The document explains the strategy that both tackles immediate problems and also shapes the transport system to meet the much longer-term transport challenges that are critical for future prosperity and way of life. Chapter 4 looks at the national framework, paragraphs 4.9 and 4.10 identify the key strategic national corridors as follows:-

4.9 However, cities do not function in isolation, and their relationship with their rural hinterlands is vital in their continued success. Eddington also emphasised the economic importance of the key inter-urban corridors and international gateways. 4.10 Using these start points, our analysis has led us to identify a number of components of the transport infrastructure that, collectively, are critical to the functioning of the system as a whole and to the economic success of the nation. These are: the ten ports and seven airports (which together make up our key international gateways) through which most people and goods enter and leave this country; our ten biggest conurbations, which contain about one-third of the population of Great Britain; and the 14 national transport corridors that connect them and other areas with strong economic growth and inward investment (such as the Thames Valley and south Cambridgeshire) with each other and with the principal freight distribution centres.

6.8 The ‘strategic core’ of the transport system is illustrated in Figure 4.1

and Tables 4.1– 4.3 of the document. The Strategic National Corridors are illustrated in Fig 4.1. This shows ‘Corridor 11, Haven Ports to the Midlands’ intersecting with ‘Corridor 10 London to the East midlands, Yorkshire, North East and Scotland’ and ending with a junction with ‘Corridor 8, London to the West Midlands, North Wales, North West and Scotland’.

6.9 This illustrates the strategic nature of the Felixstowe to Nuneaton rail

route connecting the Haven Ports via the East Coast main line and West Coast Main Line to the major conurbations of the Midlands, North-west and North-east England and Scotland.

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6.10 Government policy towards the railways was set out in the ‘Delivering a

sustainable Railway’ white paper (DfT July 2007). In the executive summary to this White Paper the principle of delivering a sustainable railway is set out as follows:-

“Sustainability demands a broader look at priorities for the railway alongside other modes, to find the best balance between the needs of the economy, society and the environment. Safety, reliability and cost are permanent priorities for the railway. But increasing capacity is the most urgent investment need – to accommodate record passenger numbers, allow rail to contribute to low-carbon economic growth, and move towards the service quality that more exacting consumers increasingly demand Delivering such a railway involves ensuring that investments are targeted and sustained, to deliver steady and efficient improvement against a long-term sense of direction, based on the best evidence available today. This will provide a rail industry with the flexibility to react to longer-term challenges, while not getting ahead of the realistic ability to predict.”

6.11 The White Paper deals with rail freight in chapter 9 and sets out the policy for establishing a Strategic Freight Network to accommodate freight trains with higher axle loading, and greater loading gauge. A key element of this network is the Felixstowe to Nuneaton route. It enables an alternative route to be made available from the current route that freight trains follow via London and at the same time improves capacity to serve the Haven ports.

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7 Development Plan Policies 7.1 The East of England Plan (to 2021) is the RSS relevant to the area in

which the Ipswich Chord is located. 7.2 At the time of preparing this statement the High Court have ruled, 7

February 2011, that the Secretary of State’s intention to abolish the RSS is a 'material consideration' which can be taken into account by local planning authorities and planning inspectors when making decisions. What weight to give to this intention is a matter for the decision taker. It should however be noted that the decision of the High Court of the 7 February 2011 is, itself, the subject of an appeal to the Court of Appeal with a hearing date set between the 4 and 6 May 2011.

7.3 On the basis of the High Court decision on the 7 February 2011 and in

the absence of an NPS for transport it is considered that the RSS is material to the decision that has to be made on the DCO. The DCO whilst having a mainly local impact in terms of its construction and visual appearance is of both national and regional importance in terms of the outputs that it achieves. It is supported at the national and regional level because of its strategic importance. As set out in the Assessment of Need this is a key element in the National Strategic Rail Freight network and as such national and regional policies must carry considerable weight in making a decision.

. 7.4 Policies in the East of England Plan relevant to the proposed

development are:- Policy T1: Regional Transport Strategy Objectives & Outcomes – states that the objectives of the RTS give a clear priority to increasing passenger and freight movement through more sustainable modes by ‘managing travel behaviour and the demand for transport to reduce the rate of road traffic growth’ and ‘encouraging efficient use of existing transport infrastructure’. Successful achievement of these objectives will lead to the following outcomes; ‘increased proportion of freight movement by rail’ and ‘safe, efficient and sustainable movement of passengers and freight to and from the region’s international gateways’. Policy T10: Freight Movement – ‘Priority should be given to the efficient and sustainable movement of freight, maximising the proportion of freight carried by rail and water where those are the most efficient modes: high priority should be given to measures to provide adequate rail freight capability and capacity on routes to the region’s major ports of…Felixstowe’.

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Policy T11: Access to Ports – ‘Access to the region’s ports should be managed and enhanced to support their development and enable them to contribute to national and regional objectives for economic growth and regeneration. In accordance with Policy T10, a key priority will be to maximise the proportion of freight, particularly longer distance freight, by modes other than road, consistent with commercial viability’. Policy HG3: Transport Infrastructure - Priorities for transport in the sub-region should focus on the urban centres of Colchester and Ipswich and on the strategic infrastructure and services to facilitate access to and from the Haven Ports.

7.5 The Ipswich Local Plan (November 1997) - Saved Local Plan Policies contains policies saved under the Planning & Compulsory Purchase Act 2004.

7.6 This local plan states that two of the key objectives to be achieved in

planning for movement and infrastructure are ‘to maintain access within the town and minimise congestion’ and ‘to provide for an environmentally efficient transport system in terms of energy conservation and reduced levels of pollution’.

7.7 The local plan makes no specific reference to rail freight with regard to

achieving the above objectives. However, the policies aimed at doing so (see below) highlight the importance placed upon the reduction of traffic congestion, one of the key benefits the North Ipswich Chord will enable both in the Ipswich area and beyond:-

Policy T20: Roads – This states that ‘each development proposal will be assessed in terms of its impact on the road network in respect of traffic capacity, safety and environmental impact of generated traffic. The Council will require mitigating measures to be provided to the satisfaction of the highway authority where necessary’.

Policy T21: Movement of Freight & Goods Vehicles – This states that ‘developments which involve the movement of bulky or high volume goods will be encouraged to locate at sites on the edge of the Town which are well related to the main road network and at sites which have potential for rail access’.

7.8 The Harris factory site is allocated for employment purposes within the

local plan. However, Policy EMP4 states that ‘the Council will allow non-employment uses including retail within the sites listed under Policy EMP2 and Proposal EMP5 and WD 16 providing they are ancillary to the principal employment use’.

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7.9 The Ipswich Local Plan First Deposit Draft (November 2001) was part

of a process to replace the Ipswich Local Plan (1997) with a new Ipswich Local Plan (2005). However, when the Local Plan system was phased out and replaced with the new Local Development Framework system, the new Ipswich Local Plan was not taken through to completion. Although not an adopted plan, The First Deposit Draft therefore is an indication of the direction of travel of the Council in planning policy terms. On the subject of movement of goods and freight vehicles, this document makes reference to how ‘the Strategic Rail Authority and Railtrack are currently investigating opportunities to improve conditions for rail freight movement through Ipswich’ and includes Policy T4 Site No. 11.24 – This states that ‘land will be safeguarded to allow the construction of a new rail link between the main line and the East Suffolk line at ‘Bacon Junction’’.

Core Strategy – Submission Version

7.10 Ipswich Borough Council submitted its Core Strategy and Policies DPD and accompanying Proposals Map as part of its Local Development Framework (LDF) to the Secretary of State on 26th March 2010. The following policy is included:-

Policy CS20: East – West Transport Capacity states that ‘the Council also supports the completion of the upgrading of the Felixstowe to Nuneaton rail line. To assist with this the Council will protect, for rail use, the line of the 'Bacon Chord' near Hadleigh road, Ipswich.

7.11 Babergh District Council policies are not included as the only part of the authorised works which lie within their area is where the new junction is formed with the GEML adjacent to the northern end of Europa Way. The boundary between Babergh and Ipswich is formed by the eastern boundary of the existing GEML from the north to the River Gipping.

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8 Analysis in accordance with the Development Plan and Other Material Considerations

8.1 At the national level, the policy of sustainable development as expressed in PPS1 and its accompanying Annex, emphasises first, the objective to reduce the need for travel and, secondly, to encourage a modal shift towards more sustainable forms of transport. Sustainability is also about creating the environment for economic growth. The railway is generally recognised as being a more sustainable transport system than the private car/lorry or plane. To achieve a modal shift primarily from the private car/lorry but also from air travel to trains, the railway system needs to be made more attractive to users in terms of reliability, and capacity. The capacity of the links between the key gateways into the country and the major urban areas of the country was identified in the Eddington Report as a major influence on the country’s economic performance. The Haven ports of Felixstowe and Harwich International comprise one of the key gateways into the country with the need to ensure adequate links from there to the Midlands, North and North-West as well as London being key to economic growth.

8.2 The Government’s strategic transport policy as set out in the White Paper ‘Delivering a Sustainable Transport System’, identifies 14 key corridors including the Haven Ports to the Midlands. This corridor is served by the cross country railway which runs from Felixstowe to Nuneaton (F2N) via Ely, Peterborough and Leicester. This route is the subject of a number of current upgrade projects to improve capacity and to gauge clear the line to enable larger containers to be transported by rail on this route. These projects include the gauge clearance of the route between Peterborough and Nuneaton which was completed in April 2011 The section of line from Felixstowe to Peterborough is already gauge cleared. Various improvements to signalling, the provision of passing loops at Ely and the provision of an additional chord line at Nuneaton to enable freight trains going north on the West Coast Main Line (WCML) to gain the WCML without having to cross at grade the WCML are all taking place. The work at Nuneaton was the subject of a Transport and Works Order under the Transport and Works Act 1992. The Order was made in June 2010 and work started on site in late 2010.

8.3 The F2N route provides connection both to the ECML at Peterborough and the WCML at Nuneaton. It therefore forms an important link between the Haven ports and routes to, Yorkshire, North East and Scotland and to the West Midlands, North Wales, North West and Scotland.

8.4 The provision of additional capacity to meet current and future demand for the movement of freight by rail to meet sustainability objectives is therefore a key requirement.

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8.5 The importance to the regional economy of the continuing prosperity of the Haven ports is spelt out in the RSS. This prosperity is linked to the need to ensure that the planned for future growth of the Haven Ports is adequately mirrored in the growth in capacity of transport links to the Haven Ports. As indicated in paragraph 8.2 above there is a programme of works to upgrade the key strategic freight route from the Haven Ports to the Midlands north-west and Scotland as part of this increase of capacity. A key capacity constraint for future growth of freight traffic is the operation of Ipswich Freight yard where currently freight trains have to enter, the train locomotive ‘runs round’ the train and leaves in the same direction it entered. The chord line would eliminate this time consuming movement and provide capacity for future growth depending on further improvements elsewhere on the line. This will facilitate the future growth of the Haven ports as set out in policies T1, T10, T11 and HG3 of the RSS (see paragraph 7.4 above).

8.6 The Ipswich Local plan adopted in 1997 makes no specific reference to the Ipswich North Chord but does contain policies designed to encourage the movement of goods by rail rather than road at a more sub-regional scale, policies T20 & T21.

8.7 The Ipswich Local Plan First Deposit Draft (November 2001) as indicated in paragraph 7.9 above was not pursued to adoption because of the change in the development plan process brought about by the Planning and Compensation Act 2004. Nevertheless it represents the then thinking of the local planning authority, containing a specific policy referring to the need for a new rail link between the GEML and ESL in policy T4 (see paragraph 7.9 above).

8.8 The Draft local plan contained the following policy:-

T24 SITE No. 11.24. Land will be safeguarded to allow the construction of a new rail link between the main line and the East Suffolk line at ‘Bacon Junction’.

8.9 The supporting text for this policy states:-

“11.117 It is likely that the movement of freight by rail will increase in the Ipswich area. In particular, the Strategic Rail Authority is developing proposals for better inter-regional freight connections between Felixstowe and Nuneaton in the West Midlands. Also, development of new port facilities at Bath Side Bay in Dovercourt represents in effect a major expansion of the capacity of the Harwich area to handle freight. The East-West Rail project referred to earlier will provide the opportunity for further movement of freight by rail. Further rail based movement can be expected as a result of these projects and proposals.

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11.118 The Strategic Rail Authority and Railtrack are currently investigating opportunities to improve conditions for rail freight movement through Ipswich. The possibility of building a new rail link at ‘Bacon Junction’ on the site of the former Harris bacon factory between the main line and the East Suffolk line is being investigated, as is the possibility of increasing the capacity of Ipswich Tunnel. Both schemes could have implications for the future use of the Upper and Lower Goods Yards in Ipswich.”

8.10 A Core Strategy and Policies DPD and accompanying Proposals Map

as part of its Local Development Framework (LDF) has been submitted to the Secretary of State.

8.11 The document builds on the Ipswich Local Plan First Deposit Draft (November 2001) with regard to the rail chord, the supporting text for policy CS20 (see paragraph 7.10 above) states:-

‘the Felixstowe to Nuneaton rail line is part of the Trans-European Network and there are longstanding proposals to upgrade this route - particularly to enable greater rail based freight movements from Felixstowe port. Currently all freight trains from Felixstowe need to come into or go through Ipswich station. The 'Bacon Chord' near Hadleigh Road, would be a short piece of new track that would enable trains to go direct from Felixstowe onto the Peterborough line without having to go into Ipswich station’

8.12 The two documents the Ipswich Local Plan First Deposit Draft (November 2001) and the submitted Core Strategy and Policies DPD whilst not forming part of the adopted development plan must carry considerable weight in determining the DCO as they represent the most up to date position of the local planning authority, bearing in mind that the adopted local plan dates from 1997 some fourteen years ago.

8.13 The Ipswich Chord therefore accords with the RSS component of the development plan and the emerging development plan as represented initially by the Ipswich Local Plan First Deposit Draft (November 2001) and the submitted Core Strategy and Policies DPD.

8.14 The former Harris factory site was allocated for employment purposes in the Ipswich Local Plan (November 1997). However the more recent draft plans the Ipswich Local Plan First Deposit Draft and Core Strategy and Policies DPD anticipate that part of the site will be required for the construction of the chord line.

8.15 The construction of the chord line does not prevent the implementation of three of the four extant planning consents for commercial development on the site. The road access (lpa ref 08/00696/FUL see paragraph 5.4 above), development on plot 1 (lpa ref 08/00929/FUL see paragraph 5.6 above) and development on plot 2 (lpa ref

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08/00928/FUL see paragraph 5.5 above) could all take place before, during or after the construction of the chord line. There would need to be an agreement on traffic management should the construction of both sites coincide. In addition there may need to be temporary arrangements to manage surface water drainage and the relocation of reptiles should the railway chord and development of the rest of the site takes place concurrently. This may involve variations to some of the conditions attached to those consents particularly in relation to the sequence of events. Informal discussions with the local planning authority have indicated that given the situation a flexible approach would be taken in considering any such variation.

8.16 The permanent relationship of the chord line and commercial development of the site can be satisfactorily accommodated. The maintenance access under the railway provides for a permanent pedestrian and cycle access between Hadleigh Road and the River Gipping (see proposed requirement 13 in Schedule A part 2 of the draft DCO). This same access is designed to facilitate the surface water drainage of the site. The land between the new rail chord and river Gipping is sufficient to accommodate the sustainable urban drainage systems, reptile re-location and wildlife area required by the planning consents.

8.17 Implementation of the fourth planning consent for the re-use of the existing building (lpa ref 08/00970/FUL see paragraph 5.7 above) would no longer be feasible as part of the building is required for the embankment. In practice the whole building will have to be demolished. However on completion of the rail chord the majority of the site will be available as a cleared site for re-development. This will mean that instead of adapting an obsolete building for a new use a purpose designed building could be constructed.

8.18 The railway chord does not prevent the commercial development of the rest of the Harris factory site although it is acknowledged there will have to be a degree of cooperation if the two developments are to take place concurrently. The railway chord does also reduce the amount of land available for development from approx 17 acres to 11 acres. However not all the 6 acres is ‘lost’ to development. Within this six acres provision can be made for the sustainable urban drainage, wildlife site, and reptile relocation site, all conditions of the planning consents (see Appendix 1)

8.19 The extant planning consent on the land at Europa Way (lpa ref 05/00599/FUL see paragraph 5.9 above) could not be implemented if the railway chord is built as a strip of land along the western boundary of the site adjacent to the GEML is required to widen the embankment to cater for the additional two tracks. The extant planning consent was for one large building accommodating the various uses granted consent. It is therefore acknowledged that no part of the development could be carried out. However the land required permanently is only 1538m2 of the total site (14487m2) and once the railway had been built

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the site would be capable of development in a similar, albeit with less accommodation, manner to the extant consent. It will be noted that although planning permission was granted in July 2006 no start has been made on the development and the consent lapses on the 13 July 2011.

8.20 The rest of the railway chord occupy’s land which lies between the GEML and the rear of the petrol station, supermarket and factory units on Boss Hall estate. It is acknowledged that during construction there will be a temporary impact on a number of the units on the Boss Hall Estate near to the construction of the two bridges over the River Gipping, mainly relating to access and loss of car parking. The only permanent loss of currently active employment land is the unit immediately adjacent to the River Gipping, which in the permanent situation loses 200m2 of its parking, loading/unloading facilities. It is acknowledged that this may make the property a less attractive unit but would nevertheless provide employment opportunities”

8.21 The marginal loss of land for employment purposes (Harris Factory site and Boss Hall Estate) and commercial/housing development (Europa Way) is not significant and does not outweigh the benefits of the construction of the railway chord.

8.22 The impact of the new railway embankment on the riverside path and cycle route along the river Gipping is considered in the ES volume 2. It should be noted that within the limits of the land acquired for the works it is proposed to make passive provision for a ramp to replace the steps alongside the river sluice gate which is part of the existing flood defense system. The removal of the steps is an aspiration of Ipswich Borough Council to improve the attractiveness of the riverside walk.

8.23 The new bridge over the Sproughton Road has been designed to facilitate the future widening of the footpath on the north side, should at some future date the existing rail bridge need replacing. This has lead to the need to carefully consider the construction of the new bridge to both minimize its impact on the operation of the existing GEML whilst facilitating the possible future replacement of the existing bridge. The final design seeks to minimize its visual impact and merge with the existing bridge whilst facilitating a possible future replacement of the existing bridge.

8.24 The replacement bridge over the river Gipping has been designed to enable the bulk of the work to be done whilst keeping the East Suffolk line open. The ESL is the only route to Felixstowe and it is therefore imperative to keep disruption on this line to a minimum. Whilst the basic structure of the bridge will be concrete it will be clad in brickwork.

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9 Requirements

9.1 Set out in Part 2 of Schedule A to the DCO are the requirements proposed to be attached to the DCO. This section sets out the reasoning behind each of the requirements.

9.2 Requirement 2 provides for the development to be divided into a number of stages to facilitate the start of different parts of the project at different times without the need for full details of all matters for the whole scheme having first to be approved. This is particularly important in a linear scheme.

9.4 Requirement 3 lists requires the development to be constructed in accordance with the design drawings submitted with the application which depict the physical development of the authorised works for which development consent is sought.

9.5 Requirement 4 provides for the landscaping of the authorised development. The requirement is cross-referenced to the mitigation proposed in the ES. In particular paragraphs 1.6.9 – 1.6.16 of Chapter 8 Volume 3 of the ES set out a series of detailed standards which the landscape scheme should comply with. With the level of detail cross-referred to in the ES it is considered unnecessary to refer to ‘appropriate British Standards or other recognised codes of practice’ as referred to in model requirement 8 in Schedule 4 to The Infrastructure Planning (Model Provisions) (England and Wales) Order 2009. It should be noted that the land between the railway embankment and the river Gipping is not required permanently for the railway. It is anticipated that this area of land will eventual include the sustainable urban drainage system, reptile relocation area and wildlife area which are the subject of planning conditions on the redevelopment of the Harris factory site and will be the responsibility of the developer of that site (see section 8 above). As such the railway embankment will provide a ‘green’ backdrop to this area.

9.6 Requirement 5 provides for the implementation and maintenance of the landscaping scheme the subject of requirement 4. It will be noted that paragraph 1.6.17 of Chapter 8 Volume 3 of the ES sets out that the landscape will be maintained in accordance with Network Rail’s trackside maintenance standard.

9.7 Requirement 6 ensures that the necessary traffic control is in place before construction of the railway embankment requiring access from Hadleigh Road commences. The requirement arises from a specific request of the Highway Authority.

9.8 The ES at volume 2 paragraph 12.8.1 sets out the need to provide a watching brief for archaeological remains. Requirement 7 secures that a written scheme of investigation shall be agreed where there is excavation.

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9.9 The Contract Requirements – Environment (CRE) is Network Rail’s own internal comprehensive means of controlling the construction impact of any project it carries out. The full CR-E document is included in the ES in Volume 3 Chp.15. These controls are applied whether or not the project has been subject of the need for external consent. It recognises the public interest in dealing with all aspects of the potential impact of the construction phase. To avoid duplication and the possibility of two concurrent regimes of control it is Network Rail’s preference to incorporate the CRE into a requirement such that the requirements are not only enforceable by Network Rail on its contractors but in the last resort there is an external means of enforcement by the local planning authority. In section 6 of the CRE there are various optional plans that may or may not be required depending on the nature of the project. The requirement sets out which of those optional plans are mandatory for this DCO.

9.10 Requirement 9 sets out a specific restriction on morning peak hour access by HGV’s from Hadleigh Road to mitigate impact on peak hour traffic flows.

9.11 The ES only identifies one specific situation where operational noise may impact on the amenities of residential properties. This is close to Sproughton Road bridge where there is a potential for freight trains to be held at signals. Requirement 10 sets out a standard by which any property potential affected in this way will be mitigated.

9.12 Requirement 11 sets out the mitigation measures to be taken in respect of both potential contaminated land identified in the ES and any contamination revealed during construction of the authorised works.

9.13 Requirement 12 sets out the Ecological Management Plan required by the ES.

9.14 Requirement 13 relates to the planning conditions imposed by Ipswich Borough Council on the development of the former Harris factory site which require the provision of a footpath/cycleway between Hadleigh Road and the River Gipping to be provided in perpetuity. It is understood that Ipswich Borough Council have an aspiration to build a cycle/footpath bridge across the River Gipping to improve connectivity in this part of Ipswich. Network Rail would acquire permanently only the land over which the Ipswich Chord runs. This includes the land required for the maintenance access under the embankment. So as not to frustrate the provision of a future footpath/cycleway the requirement makes provision for the route under the railway to be used in perpetuity subject to the rest of the route being provided on the implementation of the redevelopment of the Harris factory site footpath/cycleway.

9.15 Requirement 14 makes provision for details of the finishes, including anti-graffiti measures, to the three bridges to be built, the railway bridge over Sproughton Road, reconstructed and new rail bridges over the River Gipping to be approved before work commences.

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10 Conclusion 10.1 The proposed Ipswich Chord accords with the RSS part of the

Development Plan. It accords with the emerging development plan as represented by the Local Plan First Deposit Draft and Core Strategy and Policies DPD. There is a minor loss of land for employment and commercial development which is of a minor nature and does not outweigh the general accord of the Ipswich Chord with the development plan.

10.2 The impact on the riverside walk is kept to a minimum with the impact

of the new river bridge balanced against the passive provision of a future ramp to replace the steps at the sluice gate.

10.3 The new bridges have been designed to fit in to the street scene and

maintain the more traditional appearance of the local railway infrastructure.

10.4 Conditions are proposed to mitigate the impact of the development during its construction phase and impact on wildlife and archeological matters of interest.

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Appendix 1: The four planning permissions relating to the former Harris Meat Factory site and a plan showing the relationship of the access road and three sites

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GLOSSARY DCLG Department of Communities and

Local Government DCO Development Consent Order DfT Department for Transport ES Environmental Statement (Application

Documents ref 4.1-4.4) ESL East Suffolk Line F2N Felixstowe to Nuneaton freight rail

route GEML Great Eastern Main Line HLOS High Level Output Statement INC Ipswich North Chord LB Localism Bill LDHS Long Distance High Speed MIPRWP “Major infrastructure planning reform,

Work Plan”, Department of Communities and Local Government Dec 2010

NPS National Policy Statement PA2008 Planning Act 2008 RSS Regional Spatial Strategy RUS Route Utilisation Strategy SFN Strategic Freight Network WCML West Coast Main Line

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BIBLIOGRAPHY

i. The Department of Communities and Local Government, “Major Infrastructure Planning Reform Work Plan”, published December 2010.

ii. The Department of Communities and Local Government, “Localism

Bill”, published 13 December 2010. iii. The Department of Communities and Local Government, “The Plan for

Growth”, published 24 March 2011. iv. The Department of Transport, “Delivering a Sustainable Railway”, July

2007.

v. Ipswich Borough Council, “Ipswich Local Plan, Saved Local Plan” Policies, November 1997.

vi. Ipswich Borough Council, “Ipswich Local Plan, First Deposit Draft”,

November 2001. vii. Ipswich Borough Council, “Ipswich Local Plan”, 2005.

viii. Ipswich Borough Council, “Ipswich Core Strategy and Policies

Development Plan Document”, submitted to the Secretary of State in March 2010.

ix. The Department of Communities and Local Government, “Planning

Policy Statement 1: Delivering Sustainable Development”, January 2005.

x. The Department of Communities and Local Government, “Planning

Policy Statement 1: Delivering Sustainable Development, Planning and Climate Change”, supplement published December 2007.

xi. The Department of Communities and Local Government, “Planning

Policy Guidance 13: Transport”, April 2001. xii. The Department of Transport, “Delivering a Sustainable Transport

System”, November 2008. xiii. Sir Rod Eddington, “The Eddington Transport Study”, December 2006. xiv. Sir Nicholas Stern, “Stern Review on the economics of climate

change”, October 2006. xv. East of England Regional Assembly, “East of England Plan 2001 to

2021”, May 2008. xvi. Ipswich Borough Council, “Core Strategy and Policies DPD Proposals

Map”, September 2009.

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xvii. Ipswich Borough Council, “Local Development Framework”, March

2010.

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3.9 Network Rail (Ipswich Chord) Order - Planning Statement

Documents

Transcript of 3.9 Network Rail (Ipswich Chord) Order - Planning Statement