Strategic Environmental Assessment and Sustainability Appraisal - Proposed Submission Core Strategy and Policies DPD

Ended on the 5 March 2015

3 SUSTAINABILITY APPRAISAL

>3.1 Stages in the SA Process

Although there are formalised approaches for both SA and SEA, only the latter has a legal obligation to perform certain activities as stipulated in the SEA Directive. These legal obligations have been adhered to throughout the SA process by following a series of prescribed stages, through which the elements of the Core Strategy have been appraised using SA Objectives (Table 3-2 provides further detail) ^[1].

Table 3-1 presents a summary of the key stages of the SA process, together with the SEA Directive requirements for each stage. Reference is given to where the requirements have been addressed within this SA Report.

Table 3-1 Stages in the SA Process and SEA Directive Requirements

SA Stage	Key SEA Directive Requirements	Relevant Section of the SA Report	Application to the Core Strategy
Stage A: Setting the context and objectives, establishing the baseline and deciding on the scope
A1: Identifying other relevant policies, plans and programmes and sustainability objectives	The Environment Report should provide information on: "the relationship (of the plan or programme) with other relevant plans and programmes" (Annex 1(a)) "the environmental protection objectives, established at international (European) Community or Member State level, which are relevant to the plan or programme and the way those objectives and any environmental considerations have been taken into account during its preparation" (Annex 1(e))	Chapter 2 and Appendix A.	Stage A corresponds to the scoping stage of the SA and the findings of this stage are presented in the Scoping Report and subsequent Scoping Letter that was consulted upon in October / November 2013 and September 2014 respectively. During these stages the scope of the SA for the Core Strategy was defined.
A2: Collecting baseline information	The Environment Report should provide information on: "relevant aspects of the current state of the environment and the likely evolution thereof without its implementation of the plan or programme' and, 'the environmental characteristics of the areas likely to be significantly affected" (Annex 1(b), (c)) " any existing environmental problems which are relevant to the plan or programme including, in particular, those relating to any areas of a particular environmental importance, such as areas designated pursuant to Directives 79/409/EEC and 92/43/EEC" (Annex 1 (c))	Chapter 2 and Appendix B
A3: Identifying sustainability issues and problems		Chapter 2
A4: Developing the SA Framework	N/A	Chapter 2
A5: Consulting on the scope of the SA	The authorities referred to in Article 6(3) shall be consulted when deciding on the scope and level of detail of the information which must be included in the environmental report.(Article 5.4)	N/A
Stage B: Developing and Refining Options and Assessing Effects
B1: Testing the Core Strategy's objectives against the SA Framework	The Environment Report should consider "reasonable alternatives taking into account the objectives and the geographical scope of the plan or programme" and give "an outline of the reasons for selecting the alternatives dealt with" (Article 5.1 and Annex I(h)) In the Environmental Report, "the likely significant effects on the environment of implementing the plan or programme ... and reasonable alternatives ... are [to be] identified, described and evaluated" (Article 5.1)	Chapter 3	Stage B of the SEA process is linked to the overall production of the Core Strategy which includes the development of plan options and the selection of the preferred options. There has been a considerable degree of interaction between the plan-making and SA teams during this stage in the process. This has enabled potential adverse effects of the Core Strategy to be avoided/minimised and potential sustainability benefits maximised. A separate Annex has been produced by Ipswich Borough Council which explains how the mitigation measures identified have been addressed in the Core Strategy.
B2: Developing the Core Strategy Options
B3: Predicting the effects of the Core Strategy
B4: Evaluating the effects of the Core Strategy
B5: Considering ways of mitigating adverse effects and maximising beneficial effects	Annex I (g) states that it should also include "measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the environment of implementing the plan or programme..."
B6: Proposing measures to monitor the significant effects of implementing the Core Strategy	The Environmental Report should provide information on "a description of the measures envisaged concerning monitoring" (Annex I (i))
Stage C: Preparing the SA Report
C1: Preparing the SA Report	Article 5.1 contains the requirement for an Environmental Report to be produced where an assessment is required. The environmental report " shall include the information that may reasonably be required taking into account current knowledge and methods of assessment, the contents and level of detail in the plan or programme, its stage in the decision-making process and the extent to which certain matters are more appropriately assessed at different levels in that process in order to avoid duplication.." (Article 5.2). Details of the information to be given in the Environmental Report are provided in Annex 1.	This SA Report represents the required Stage C output.	The SA Report will be produced in line with the requirements of the SEA Directive for producing an Environmental Report. A Non-Technical Summary is also provided.
Stage D: Consultation on the Core Strategy and the SA Report
D1: Public participation on the proposed submission documents	Article 6 contains the requirements for the draft plan or programme and the environmental report to be made available to statutory authorities and the public. They should be given an ' early and effective opportunity within time frames to express their opinions' (Article 6.2).		The SA Report and the Core Strategy will be consulted upon in accordance with Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012.
D2: Appraising significant changes resulting from representations	N/A	N/A	Following the receipt of representations, the SA Report may need to be updated to reflect comments received. The SA Report will need to be updated to accompany the submission (Regulation 22) version of the Core Strategy. It will be essential for the SA Report and the Strategy to remain consistent.
D3: Making decisions and providing information	N/A	N/A
Stage E: Monitoring the significant effects of implementing the Core Strategy
E1: Finalising aims and methods for monitoring	"Member States shall monitor the significant environmental effects of the implementation of plans and programmes... in order, inter alia, to identify at an early stage unforeseen adverse effects, and to be able to undertake appropriate remedial action" (Article 10.1)		Monitoring undertaken for the SA process should feed into the Authority Monitoring Report (AMR).
E2: Responding to adverse effects

The following sections detail the activities that have been, and are proposed to be, undertaken at each stage of the SA process. This provides context and background to the SA including its agreed scope, the methodology for the appraisal of the Core Strategy, and the technical limitations to the appraisal.

(4) 3.2 Stage A: Setting the Context, Establishing the Baseline and Deciding on the Scope

3.2.1 Review of Plans, Policies and Environmental Protection Objectives

The box below stipulates the SEA Directive requirements for this stage of the process.

Box 1: SEA Directive Requirements for the Review of Plans Programmes and Environmental Protection Objectives

The SEA Directive requires that the SEA covers:

'an outline of the contents, main objectives of the plan or programme and relationship with other relevant plans and prgorammes' (Annex 1 (a)).

'the environmental protection objectives, established at international, Community or Member State level, which are relevant to the plan or programme and the way those objectives and any environmental considerations have been taken into account during its preparation' (Annex 1 (e))

A review of other plans and programmes that may affect the preparation of the Core Strategy has been undertaken in order to contribute to the development of both the SA and the DPD. This included:

Identification of any external social, environmental or economic objectives, indicators or targets that should be reflected in the SA process.
Identification of any baseline data relevant to the SA.
Identification of any external factors that might influence the preparation of the plan, for example sustainability issues.
Identification of any external objectives or aims that would contribute positively to the development of the Core Strategy.
Determining whether there are clear potential conflicts or challenges between other identified plans, programmes or sustainability objectives and the Core Strategy.

The review included documents prepared at international, national, regional and local scale (within Ipswich). As part of the SA process consideration has also been given to plans relevant to local authority areas adjoining Ipswich due to the potential implications of the Core Strategy in relation to adjoining areas (particularly relevant to Policies CS2 and CS7 discussed later in this SA Report). This also reflects guidance contained in the Planning Practice Guidance which states ' The area likely to be affected may lie outside the local planning authority boundary and plan makers may need to obtain information from other local planning authorities .' ^[2] The latest Scoping Report produced for Suffolk Coastal is available at http://www.suffolkcoastal.gov.uk/yourdistrict/planning/review/sustainability-appraisal/ and for Mid Suffolk and Babergh is available at http://www.midsuffolk.gov.uk/assets/UploadsMSDC/Economy/Strategic-Planning-Policy/LDF/DPDs/Dm-Allocations-SEA-SR.pdf . A PDF of these documents can be provided upon request as Appendices G and H of this report.

International Plans and Programmes

A review was undertaken of key International Conventions and European Directives that could potentially influence the development of the Core Strategy and the SA. European Directives are transposed into national legislation in each individual Member State and, therefore, there should be a trickle-down effect of the key principles and an application to the relevant national, regional and local circumstances in other planning documents.

National Plans and Programmes

A review was undertaken of relevant White Papers, plans and strategies. One of the most important documents reviewed was the UK Sustainable Development Strategy ^[3] which outlines the over-arching Government objective to raise the quality of life in our communities.

Central Government establishes the broad planning guidelines and policies for a variety of different topics which are now brought together in the National Planning Policy Framework (NPPF). The NPPF streamlines former national planning policy into a consolidated set of priorities to consider when planning for and deciding on new development.

It sets national priorities and rules only where it is necessary to do so. It aims to ensure that planning decisions reflect genuine national objectives - such as the need to safeguard the natural environment, combat climate change, and to support sustainable local growth - while allowing for local authorities and communities to produce their own plans, reflecting the distinctive needs and priorities of different parts of the country. The principle of sustainable development is at the heart of the NPPF.

The NPPF guidance is structured around the following sections:

Building a strong, competitive economy;
Ensuring the vitality of town centres;
Supporting a prosperous rural economy;
Promoting sustainable transport;
Supporting high quality communications infrastructure;
Delivering a wide choice of high quality homes;
Requiring good design;
Promoting healthy communities;
Protecting Green Belt land;
Meeting the challenge of climate change, flooding and coastal change;
Conserving and enhancing the natural environment;
Conserving and enhancing the historic environment;
Facilitating the sustainable use of minerals;
Plan-making; and
Decision-taking.

Regional Level Plans

A wealth of different plans and strategies have been produced at the regional (East Anglia/East of England) and county (Suffolk) level covering a variety of topics including; housing; economic development and performance; climate change (including flood risk); renewable energy; innovation; rural development; waste management; accessibility; equality and diversity; health; waste; cultural provision and diversity; and physical activity. All of the objectives of these plans as well as some of the challenges they raise need to be taken on board and driven forward by the borough as appropriate. However, it must be noted that the overarching goals of some of these plans and strategies may be outside the remit of the Core Strategy which forms only an individual part of a number of different vehicles trying to deliver regional and sub- regional targets.

The Localism Act was granted Royal Assent on 15th November 2011. This Act seeks to rescind some regional planning documents, and as such, the East of England Plan (Regional Spatial Strategy) (2008) has been revoked.

Local Policy

Plans produced at the local level specifically address issues relating to the economy; health; safety; tourism; sustainable communities; housing; employment; and physical activity. The Core Strategy and the SA should draw from these documents and transpose their aims in their policies and proposals. These plans should in theory have included the main influences of international, national, regional and county level plans through the 'trickle-down effect'. They should also provide more of a local focus for the Borough. It is, through identifying these themes and incorporating them into the DPD that synergies can be achieved with other relevant documents.

Key Results from the Review

There were many common themes emerging through the review of plans, programmes and environmental protection objectives. The list below provides a summary of the main themes and issues identified:

The need to reduce greenhouse gas emissions and increase energy efficiency.
The need to ensure that new housing development meets local needs (for all sections of society).
The need to protect and enhance the vibrancy of centres.
The need for the protection and enhancement of the quality and character of urban areas.
Recognising the need for the townscape to evolve and for development to be appropriate to townscape setting and context.
Recognising the importance of improving and developing cultural assets.
The need to conserve and enhance biodiversity as an integral part of economic, social and environmental development.
The need to protect and enhance the historic environment. The Government has an overarching aim for the conservation and enjoyment of the historic environment and heritage assets.
The need to promote sensitive waste management.
The need to develop transport and infrastructure that supports sustainable growth.
The need to promote more sustainable transport choices and to improve accessibility.
The need to promote the use of renewable energy and renewable technologies in appropriate locations.
Recognising the importance of open spaces, sport and recreation and the contribution that they make to enhancing quality of life.
The prudent use of natural resources.
The need to promote and protect the water environment including issues such as quality and resource use.
The need to establish protocols and control development within areas at risk of flooding.
The need to protect and enhance air quality.
The need to promote community cohesion and to establish an area where individuals want to both live and work.
The need to adapt to the threat posed by climate change.
The need to protect and enhance biodiversity resources particularly sites of international importance e.g. Special Areas of Conservation (SACs), Special Protection Areas (SPAs) and Ramsar Sites.
The need for long-term sustainable patterns of development that provide for the economic and social needs of all populations.
The need to reduce crime and fear of crime.
The need to protect and enhance ecosystem functions and services.
Raising levels of health and well-being and promoting greater levels of physical activity.
Establishing a housing market that meets the needs of all residents.
Promoting sustainable economic development and a range of employment opportunities that meet the needs of all sectors of the population and all skills levels.
Promoting higher levels of design quality including improvements to energy efficiency.
The need to raise the quality and improve the choice of learning opportunities and the importance of education and knowledge based industries.

The European Spatial Development Perspective identified a potential conflict that is likely to prevail in all countries, irrespective of their location and this concerns balancing the social and economic claims for spatial development with an area's ecological and cultural functions to ensure that the most sustainable patterns of development are achieved. Through the SA process and the inclusion of suitable sustainability objectives, indicators and targets, it should be possible to identify where potential issues and conflicts may arise and to develop suitable policy modifications and mitigation measures.

3.2.2 The Sustainability Baseline and Key Sustainability Issues

Box 2 defines the SEA Directive requirements for this element of the process.

Box 2: SEA Directive Requirements for Baseline Data Collation

The SEA Directive requires that the SEA covers:

'the environmental characteristics of areas likely to be significantly affected' (Annex 1 (c))

'any existing environmental problems which are relevant to the plan or programme, including, in particular, those relating to any areas of particular environmental importance, such as areas designated pursuant to Directives 79/409/EEC and 92/43/EC'(Annex 1 (d)).

Methodology

Characterising the environmental and sustainability baseline, issues and context helps to define the SA Framework. It involves the following key elements:

Characterising the current state of the environment within the Ipswich area and immediate surroundings (including social and economic aspects as well as the natural environment); and
Using this information to identify existing problems and opportunities which could be considered in the Core Strategy where relevant.

The environmental, social and economic baseline was characterised through the following methods:

Review of relevant local, regional and national plans, strategies and programmes;
Data research based around a series of baseline indicators developed from the SEA Directive topics (biodiversity, population, human health, flora, fauna, soil, water, air, climatic factors, material assets, cultural heritage including architectural and archaeological heritage and landscape). This was also based on advice in Planning Practice Guidance 'Strategic environmental assessment and sustainability appraisal’ 2014, www.pas.gov.uk guidance and previous consultation recommendations from other SAs. Data has also been collated for additional socio-economic topic areas including deprivation, housing and employment to ensure that a broad range of environmental, social and economic issues are considered. The baseline data gathered for SA purposes for plans relating to Babergh, Mid-Suffolk and Suffolk Coastal authority areas has also been considered as part of the SA process. As with the review of relevant plans and programmes this is particularly relevant to policies CS2 and CS7, as discussed later in this report. This also reflects guidance contained in the Planning Practice Guidance which states 'The area likely to be affected may lie outside the local planning authority boundary and plan makers may need to obtain information from other local planning authorities.’,

^[4] ,

A detailed description of the baseline characteristics of Ipswich is provided in Appendix B. The latest Scoping Report produced for Suffolk Coastal is available at http://www.suffolkcoastal.gov.uk/yourdistrict/planning/review/sustainability-appraisal/ and for Mid Suffolk and Babergh is available at http://www.midsuffolk.gov.uk/assets/UploadsMSDC/Economy/Strategic-Planning-Policy/LDF/DPDs/Dm-Allocations-SEA-SR.pdf . A PDF of these documents can be provided upon request as Appendices G and H of this report.

Key Sustainability Issues and Opportunities

Baseline data has been used to identify the key sustainability issues and opportunities in Ipswich and the adjacent authorities. Issues and opportunities are presented in Table 3-2. Although issues / opportunities have been grouped by broad sustainability theme, many are indirectly or directly linked and therefore closely related.

Table 3-2 Summary of Key Sustainability Issues and Opportunities

SA Topic	Key Sustainability Issues	Key Sustainability Opportunities
Population	Ipswich has the highest population of all the districts within Suffolk. The level of projected population growth within Ipswich is relatively high and so a large number of new homes is considered necessary within Ipswich in order to meet the needs of all members of the population. There are potential challenges that could arise in the future relating to the type and tenure of housing provision on offer in the Borough. These issues include provision of homes for the elderly that meet needs such as accessibility, the provision of affordable homes, and the provision of smaller homes with one to two and two to three bedrooms. There is a high percentage of people under the age of 34 in Ipswich, which may have implications for provision of educational facilities, recreational facilities etc. Asian/Asian British are the main ethnic minority representing 6.3% of the population and therefore there needs to be appropriate services provision for all members of the population in terms of education, housing etc.	There are opportunities to improve the supply of housing, education, health and other community facilities within the Borough.
Education and Qualifications	Educational attainment across Ipswich is below the national average. However, the percentage of population holding recognised qualifications is average across Ipswich with numbers of those with no qualifications and achieving National Vocational Qualification (NVQ) Level 4 similar to regional and national averages. Gipping, Priory Heath, Whitehouse, Castle Hill, Stoke Park, Rushmere, Sprites and Gainsborough wards have LSOAs that fall within the 20% most deprived for education skills and training (ONS 2010 Indices of Multiple Deprivation).	There is a need to improve educational attainment in the Borough. By improving levels of educational attainment there could be wider social benefits and improvements to the local economy.
Human Health	Life expectancy from birth for males is slightly lower than the national average and life expectancy from birth for females is slightly higher than national averages. There is a need to reduce the incidence of diseases and health inequalities. Levels of teenage pregnancy are higher than regional and national levels and have implications for health service provision, housing and educational attainment. Alexandra, Westgate, Whitton, Gainsborough, Gipping and Stokes Park wards all have LSOAs within 20% of the most deprived for health deprivation and disability.	There are opportunities to improve the health of the Borough through the provision of new homes as there are links between the supply of decent housing and health. Health improvements would also benefit the local economy and would enhance overall quality of life in the Borough. Opportunities should also be sought to encourage walking and cycling.
Water	The key watercourses in the Borough are the River Gipping and Belstead Brook which both flow into the River Orwell. The Environment Agency has identified a risk of flooding on land adjacent to the Rivers Orwell, Gipping, Belstead Brook and Westerfield Watercourse. The East of England is the driest part of the country and the area is classed as being in 'severe water stress'. Water supply is critically important, not only to agriculture but to some of the businesses currently located in Suffolk. Limited water availability and increasing demands means that much of the water resource in Suffolk is considered to be fully committed, if not overcommitted, to existing users (EA). Water quality is also a key sustainability issue. Most of the central and western area of Ipswich is designated as Source Protection Zone (SPZ) 2, with two smaller areas designated as SPZ1. SPZs are used to identify those areas close to drinking water sources, where the risk associated with groundwater contamination is greatest, and are important for identifying highly sensitive groundwater areas. SPZs are also recognised within the Environmental Permitting Regulations as a zone where certain development activities cannot take place.	New developments and households within the Borough should be encouraged to minimise water use and to re-use rainwater where possible i.e. grey water recycling systems. Discussions regarding water resources availability for new developments should be undertaken with Anglian Water. Areas at risk from flooding should be protected from development that would increase that risk. New development should be encouraged to use Sustainable Drainage Systems (SuDS) to manage runoff, further reduce flood risk and help protect groundwater and surface water quality. It should be ensured that groundwater quality is protected particularly during any construction works.
Soil and Land Quality	Much of Ipswich is an urban built up environment. There is some known potentially contaminated land within the Borough. In 2011/12, there was 67.2 hectares vacant or derelict land. (141.8 hectares total including sites in use, allocated or with planning permission) (Ipswich National Land Use database 2014).	Opportunities should be sought to include allotment space within the Borough where possible. Where appropriate, opportunities should be sought to implement appropriate remediation and verification measures of contaminated land.
Air Quality	There are four Air Quality Management Areas (AQMAs) within the Ipswich Borough, all of which are designated for NO₂ exceedences. All of the AQMAs are located within central Ipswich.	Opportunities should be sought to promote the use of public transport, walking and cycling. The air quality impacts of additional traffic within Ipswich on the AQMAs and other areas of high NO₂ levels must be assessed and monitored and strategies for limiting adverse impacts on air quality identified.
Climatic Factors	A number of areas within Ipswich lie within the floodplain. Largely these areas are associated with the River Gipping and River Orwell. There are also smaller watercourses at risk of flooding - Westerfield Watercourse and Belstead Brook. There are areas at risk of flooding, some from tidal surges and some from heavy rain. This risk may continue to grow as a result of rising sea levels and increasingly heavy rainstorms that can overwhelm drainage systems and cause localised flooding unless mitigation measures are implemented. The Ipswich Flood Defence Management Strategy is a major scheme to reduce flood risk to Ipswich over the coming years. The strategy was approved in March 2006 and recommends an investment in new flood defences across Ipswich to significantly reduce flood risk to over 3,000 residential properties. Half of the projects of the scheme have been completed with an expected date to deliver the final Tidal Barrier Project in 2017 (Environment Agency). In 2011, the estimate of CO₂ emissions for Ipswich was 4.2 tonnes per capita (Dept of Energy & Climate Change, 2011 data). When compared with CO₂ emissions per capita for Suffolk in 2009, Ipswich performed better (see Appendix B). There were no applications for renewable energy developments in 2013/14 (Ipswich Borough Council, 2014).	New development should be encouraged to use SuDS to manage runoff and further reduce flood risk (particularly as some new development would be situated on previously undeveloped land). Delivery of the Ipswich tidal flood defences will also help to reduce flood risk. New developments should be encouraged to include sustainable design principles, energy efficiency and the incorporation of renewables e.g. the inclusion of solar panels and low carbon technologies. The carbon footprint of new development should be reduced.
Biodiversity, Flora and Fauna	There are three Sites of Special Scientific Interest (SSSI), one Special Protection Area (SPA), one Ramsar site, six Local Nature Reserves (LNR) and 19 County Wildlife Sites (CWS) within Ipswich (See Map 1 Sites of Ecological Importance). There is one area of ancient and semi-natural woodland along with ancient replanted woodland to the south of the Borough.	Development proposals should maximise opportunities to protect and enhance habitats and where appropriate create new habitats in order to deliver the biodiversity objectives of the relevant Biodiversity Action Plans (BAPs). Opportunities should be sought to develop and enhance the network of public open space.
Cultural Heritage	Ipswich is home to a wealth of heritage assets including those of a national and local importance. There are over 600 Listed Buildings, of which 11 are Grade I and 25 are Grade II*. There are ten Scheduled Ancient Monuments and 14 Conservation Areas (See Map 2 Cultural Heritage Assets). Several sites within Ipswich are listed on the Historic Environment Record.	It is important to ensure that the cultural heritage is protected and that cultural heritage issues are taken into consideration. Cultural heritage features should be conserved and enhanced.
Landscape/ Townscape	The majority of Ipswich's' landscape typology is urban with some areas in the north located within ancient rolling farmlands and areas in the south east located within ancient rolling farmlands and rolling estate sandlands. The town centre has changed significantly during the twentieth century and although many historic buildings were lost to make way of new developments, it is a designated Conservation Area with historic and archaeological significance. In Ipswich there are over 600 Listed Buildings, of which 11 are Grade I and 31 are Grade II* (Ipswich Borough Council, Listed Buildings in Ipswich). Listed Buildings are largely concentrated within the town centre.	It is essential that landscape and townscape character and quality is enhanced through high quality design, careful siting, the incorporation of soft landscaping and attention to boundary treatments. In addition it is important to maintain the gap between Ipswich and adjacent villages to preserve local distinctiveness. Opportunities should be sought to promote local character and distinctiveness where possible to encourage new residents.
Minerals and Waste	There are a number of waste facilities within the Borough, including, a household waste and recycling centre, a composting site and facilities for metal / end of life vehicles (not inclusive). In addition, an energy from waste incinerator is now operational at Great Blakenham (Masons Quarry) which lies approximately 3km north of the Borough boundary, therefore transport implications must be managed carefully. In 2012/13 40.8% of waste in Ipswich was recycled and composted (Ipswich Borough Council, September 2014). Reuse / recycling / composting rates were lower than those recorded for Suffolk, the East of England and England between 2008 and 2012.	Opportunities should be sought to enhance recycling and composting performance. Sustainable sourcing and waste management principles should be promoted for all new development within Ipswich.
Transportation	The Borough is well connected by transport infrastructure and public transport links. The Ipswich Local Transport Plan includes a series of key priorities addressing transport and accessibility which include encouraging the provision and use of an integrated effective transport system which maximises the use of public transport, walking and cycling and reduces the overall impact of travel on the environment.	Opportunities should be sought to reduce dependence on the private car and increase public transport use. It will be important to ensure that new development can be easily accessed by public transport. The cycling and walking network within the Borough should be expanded and enhanced.
Economy	Ipswich has a strong employment base for businesses with a slightly higher proportion than the Suffolk average of the population at the working age, but it also has a relatively higher proportion of people who are economically inactive. Employment in Ipswich exceeds the national profile in the finance, IT, transport, communications, and public administration education and health sectors. It is below the national profile in manufacturing. Ipswich has lower working age skills levels, especially at degree level (22.8%), than the county as a whole (24.4%). It is even further below the regional and national levels (29.9%) (State of Ipswich Report May 2011).A lower than average proportion of Ipswich's population are classified as managers or senior officials while caring, leisure and other service occupations along with sales and customer service occupations and process plant and machine operatives are higher than regional and national averages. The Job Seekers Allowance rate in Ipswich (2011) is high compared to Suffolk and the national figures. It is particularly high for males, between the ages of 25-49 who have been unemployed for 6-months or over. The gross weekly pay for employees in Ipswich is lower than national and regional average and the Borough has higher numbers of people claiming benefits than county and national indicators suggest (2010). The factors restricting economic growth in Suffolk in general are a lack of qualified staff and poor broadband; as well as a lack of customers, transport links, and poor quality premises (Suffolk Growth Strategy).	The economy in Ipswich needs to be diversified to broaden the economic base as the key economic sectors are identified primarily in the service sector, e.g. distribution, public administration, etc. The good transport links in the Borough should be exploited as accessibility is a key issue when encouraging new residents. There is a need to retain skilled workers and improve skills levels amongst the workforce. There are opportunities to attract private sector interest in the town to service and provide more opportunities for existing and new communities, such as more and better shops to enhance the high street, and a focus on stalled developments.
Deprivation and Living Environment	Gainsborough, Whitton, Whitehouse, Gipping, Stoke Park, Priory Heath, Bridge and Alexander wards all have LSOAs in the bottom 20% most deprived nationally (Index of Multiple Deprivation). Deprivation is a very complex issue and a number of different issues will need to be addressed for noticeable improvements to be realised. 30% of all the crime in Suffolk happens in Ipswich and 10% of all the crime in Suffolk happens in the Town Centre of Ipswich as a result of the night time economy. Ipswich also has the highest prevalence of organised crime in Suffolk including people trafficking, drug dealing and prostitution. Anti-social behaviour also forms a large percentage of crime incidents in Ipswich in June 2012. However, recorded crimes per 1000 of Ipswich's population have fallen from 106 in 2008-2009 to 77 in 2013-2014.	There is a need to tackle anti-social behaviour, and crime rates should be further reduced to enhance overall quality of life in Ipswich. This could be achieved through incorporating safety by design principles into new development and ensuring appropriate housing mixes are adopted. In addition, generally providing improved employment and educational opportunities for the local population could also contribute to improve crime rates. Access to sports facilities should be enhanced. This could have associated health benefits.
Housing	Housing costs are relatively low but have gradually increased in recent years. Median house price (July 2013) in Ipswich is £150,000, which shows an increase of 7.1% from the median price of the same time the previous year (£140,000). The average house price is lower than Suffolk (£167,000 in July 2013) and lower than that in the East of England (£178,000 August 2013 - ONS). House prices have gradually increased but incomes have not matched this rate of growth, which may lead to problems of housing affordability. The affordability of purchased homes in 2011 was a ratio of 5:7 which was less than the affordability for Suffolk 6:9, the East of England 7:6 and England 6:5 (Office for National Statistics Local Profiles). 96 dwellings (net) were completed between 1st April 2012 and 31st March 2013, 7 of which were affordable housing completions (7.3%). 59 of these dwellings were on previously developed land (61.5%) and 17 were within the central IP-One area (17.7%). Gross housing completions (before calculating those dwellings lost) were 111 (AMR 2012-2013). The number of housing completions has fallen from a peak in 2007/08 as a result of the recession and lower demand for flats in this period. Completions for 2012/13 were at the lowest level in Ipswich since 1998/99 when 60 dwellings were completed. Affordable housing completions vary from year to year influenced by the availability of funding available and Ipswich Borough Council has commenced a programme of affordable house building across the borough with 108 dwellings to be built on a site at Bader Close in east Ipswich in addition to 7 dwellings completed on Coltsfoot Road and Whitton Church Lane. The Council's adopted Core Strategy (2011) sets a target to allocate land to accommodate at least 14,000 additional residential units between 2001 and 2021 (700 dwellings p.a.). Housing delivery has averaged 653 p.a. April 2001 to March 2012. Completions peaked in 2007-08 but have fallen since then in line with the downturn and subsequent recession. The Strategic Housing Marketing Assessment 2008 which has further been updated in 2012 found there is a need for smaller one to two bedroomed homes in Ipswich to meet the needs of smaller households and an ageing population, as well as a continued need for smaller two to three bedroomed family homes. Much of recent housing development in Ipswich, however, has been in the form of one and two bedroomed apartments and in the present economic climate there is an oversupply of flats. There are 972 vacant homes in Ipswich (2014), a decrease from 1,750 in 2011/12. 2.9% of all dwellings in Ipswich were vacant in 2011/12, representing a decrease from 3.3% in 2010/11. This figure is slightly lower than the Suffolk and England average although slightly higher than the East of England average.	Housing regeneration efforts present a significant opportunity both to revitalise the housing stock, address deprivation and to improve quality of life. Development within the Borough provides opportunities to meet housing needs, particularly for family housing and to counter balance the provision of flats within Ipswich town centre.

SA Topic

Key Sustainability Issues

Key Sustainability Opportunities

Population

Ipswich has the highest population of all the districts within Suffolk.

The level of projected population growth within Ipswich is relatively high and so a large number of new homes is considered necessary within Ipswich in order to meet the needs of all members of the population.

There are potential challenges that could arise in the future relating to the type and tenure of housing provision on offer in the Borough. These issues include provision of homes for the elderly that meet needs such as accessibility, the provision of affordable homes, and the provision of smaller homes with one to two and two to three bedrooms.

There is a high percentage of people under the age of 34 in Ipswich, which may have implications for provision of educational facilities, recreational facilities etc.

Asian/Asian British are the main ethnic minority representing 6.3% of the population and therefore there needs to be appropriate services provision for all members of the population in terms of education, housing etc.

There are opportunities to improve the supply of housing, education, health and other community facilities within the Borough.

Education and Qualifications

Educational attainment across Ipswich is below the national average. However, the percentage of population holding recognised qualifications is average across Ipswich with numbers of those with no qualifications and achieving National Vocational Qualification (NVQ) Level 4 similar to regional and national averages.

Gipping, Priory Heath, Whitehouse, Castle Hill, Stoke Park, Rushmere, Sprites and Gainsborough wards have LSOAs that fall within the 20% most deprived for education skills and training (ONS 2010 Indices of Multiple Deprivation).

There is a need to improve educational attainment in the Borough. By improving levels of educational attainment there could be wider social benefits and improvements to the local economy.

Human Health

Life expectancy from birth for males is slightly lower than the national average and life expectancy from birth for females is slightly higher than national averages. There is a need to reduce the incidence of diseases and health inequalities.

Levels of teenage pregnancy are higher than regional and national levels and have implications for health service provision, housing and educational attainment.

Alexandra, Westgate, Whitton, Gainsborough, Gipping and Stokes Park wards all have LSOAs within 20% of the most deprived for health deprivation and disability.

There are opportunities to improve the health of the Borough through the provision of new homes as there are links between the supply of decent housing and health.

Health improvements would also benefit the local economy and would enhance overall quality of life in the Borough.

Opportunities should also be sought to encourage walking and cycling.

Water

The key watercourses in the Borough are the River Gipping and Belstead Brook which both flow into the River Orwell.

The Environment Agency has identified a risk of flooding on land adjacent to the Rivers Orwell, Gipping, Belstead Brook and Westerfield Watercourse.

The East of England is the driest part of the country and the area is classed as being in 'severe water stress'. Water supply is critically important, not only to agriculture but to some of the businesses currently located in Suffolk. Limited water availability and increasing demands means that much of the water resource in Suffolk is considered to be fully committed, if not overcommitted, to existing users (EA).

Water quality is also a key sustainability issue. Most of the central and western area of Ipswich is designated as Source Protection Zone (SPZ) 2, with two smaller areas designated as SPZ1. SPZs are used to identify those areas close to drinking water sources, where the risk associated with groundwater contamination is greatest, and are important for identifying highly sensitive groundwater areas. SPZs are also recognised within the Environmental Permitting Regulations as a zone where certain development activities cannot take place.

New developments and households within the Borough should be encouraged to minimise water use and to re-use rainwater where possible i.e. grey water recycling systems. Discussions regarding water resources availability for new developments should be undertaken with Anglian Water.

Areas at risk from flooding should be protected from development that would increase that risk. New development should be encouraged to use Sustainable Drainage Systems (SuDS) to manage runoff, further reduce flood risk and help protect groundwater and surface water quality.

It should be ensured that groundwater quality is protected particularly during any construction works.

Soil and Land Quality

Much of Ipswich is an urban built up environment. There is some known potentially contaminated land within the Borough.

In 2011/12, there was 67.2 hectares vacant or derelict land. (141.8 hectares total including sites in use, allocated or with planning permission) (Ipswich National Land Use database 2014).

Opportunities should be sought to include allotment space within the Borough where possible.

Where appropriate, opportunities should be sought to implement appropriate remediation and verification measures of contaminated land.

Air Quality

There are four Air Quality Management Areas (AQMAs) within the Ipswich Borough, all of which are designated for NO₂ exceedences. All of the AQMAs are located within central Ipswich.

Opportunities should be sought to promote the use of public transport, walking and cycling.

The air quality impacts of additional traffic within Ipswich on the AQMAs and other areas of high NO₂ levels must be assessed and monitored and strategies for limiting adverse impacts on air quality identified.

Climatic Factors

A number of areas within Ipswich lie within the floodplain. Largely these areas are associated with the River Gipping and River Orwell. There are also smaller watercourses at risk of flooding - Westerfield Watercourse and Belstead Brook.

There are areas at risk of flooding, some from tidal surges and some from heavy rain. This risk may continue to grow as a result of rising sea levels and increasingly heavy rainstorms that can overwhelm drainage systems and cause localised flooding unless mitigation measures are implemented.

The Ipswich Flood Defence Management Strategy is a major scheme to reduce flood risk to Ipswich over the coming years. The strategy was approved in March 2006 and recommends an investment in new flood defences across Ipswich to significantly reduce flood risk to over 3,000 residential properties. Half of the projects of the scheme have been completed with an expected date to deliver the final Tidal Barrier Project in 2017 (Environment Agency).

In 2011, the estimate of CO₂ emissions for Ipswich was 4.2 tonnes per capita (Dept of Energy & Climate Change, 2011 data). When compared with CO₂ emissions per capita for Suffolk in 2009, Ipswich performed better (see Appendix B).

There were no applications for renewable energy developments in 2013/14 (Ipswich Borough Council, 2014).

New development should be encouraged to use SuDS to manage runoff and further reduce flood risk (particularly as some new development would be situated on previously undeveloped land). Delivery of the Ipswich tidal flood defences will also help to reduce flood risk.

New developments should be encouraged to include sustainable design principles, energy efficiency and the incorporation of renewables e.g. the inclusion of solar panels and low carbon technologies. The carbon footprint of new development should be reduced.

Biodiversity, Flora and Fauna

There are three Sites of Special Scientific Interest (SSSI), one Special Protection Area (SPA), one Ramsar site, six Local Nature Reserves (LNR) and 19 County Wildlife Sites (CWS) within Ipswich (See Map 1 Sites of Ecological Importance).

There is one area of ancient and semi-natural woodland along with ancient replanted woodland to the south of the Borough.

Development proposals should maximise opportunities to protect and enhance habitats and where appropriate create new habitats in order to deliver the biodiversity objectives of the relevant Biodiversity Action Plans (BAPs).

Opportunities should be sought to develop and enhance the network of public open space.

Cultural Heritage

Ipswich is home to a wealth of heritage assets including those of a national and local importance.

There are over 600 Listed Buildings, of which 11 are Grade I and 25 are Grade II*. There are ten Scheduled Ancient Monuments and 14 Conservation Areas (See Map 2 Cultural Heritage Assets).

Several sites within Ipswich are listed on the Historic Environment Record.

It is important to ensure that the cultural heritage is protected and that cultural heritage issues are taken into consideration.

Cultural heritage features should be conserved and enhanced.

Landscape/ Townscape

The majority of Ipswich's' landscape typology is urban with some areas in the north located within ancient rolling farmlands and areas in the south east located within ancient rolling farmlands and rolling estate sandlands.

The town centre has changed significantly during the twentieth century and although many historic buildings were lost to make way of new developments, it is a designated Conservation Area with historic and archaeological significance.

In Ipswich there are over 600 Listed Buildings, of which 11 are Grade I and 31 are Grade II* (Ipswich Borough Council, Listed Buildings in Ipswich). Listed Buildings are largely concentrated within the town centre.

It is essential that landscape and townscape character and quality is enhanced through high quality design, careful siting, the incorporation of soft landscaping and attention to boundary treatments.

In addition it is important to maintain the gap between Ipswich and adjacent villages to preserve local distinctiveness.

Opportunities should be sought to promote local character and distinctiveness where possible to encourage new residents.

Minerals and Waste

There are a number of waste facilities within the Borough, including, a household waste and recycling centre, a composting site and facilities for metal / end of life vehicles (not inclusive). In addition, an energy from waste incinerator is now operational at Great Blakenham (Masons Quarry) which lies approximately 3km north of the Borough boundary, therefore transport implications must be managed carefully.

In 2012/13 40.8% of waste in Ipswich was recycled and composted (Ipswich Borough Council, September 2014). Reuse / recycling / composting rates were lower than those recorded for Suffolk, the East of England and England between 2008 and 2012.

Opportunities should be sought to enhance recycling and composting performance.

Sustainable sourcing and waste management principles should be promoted for all new development within Ipswich.

Transportation

The Borough is well connected by transport infrastructure and public transport links. The Ipswich Local Transport Plan includes a series of key priorities addressing transport and accessibility which include encouraging the provision and use of an integrated effective transport system which maximises the use of public transport, walking and cycling and reduces the overall impact of travel on the environment.

Opportunities should be sought to reduce dependence on the private car and increase public transport use.

It will be important to ensure that new development can be easily accessed by public transport.

The cycling and walking network within the Borough should be expanded and enhanced.

Economy

Ipswich has a strong employment base for businesses with a slightly higher proportion than the Suffolk average of the population at the working age, but it also has a relatively higher proportion of people who are economically inactive. Employment in Ipswich exceeds the national profile in the finance, IT, transport, communications, and public administration education and health sectors. It is below the national profile in manufacturing.

Ipswich has lower working age skills levels, especially at degree level (22.8%), than the county as a whole (24.4%). It is even further below the regional and national levels (29.9%) (State of Ipswich Report May 2011).A lower than average proportion of Ipswich's population are classified as managers or senior officials while caring, leisure and other service occupations along with sales and customer service occupations and process plant and machine operatives are higher than regional and national averages.

The Job Seekers Allowance rate in Ipswich (2011) is high compared to Suffolk and the national figures. It is particularly high for males, between the ages of 25-49 who have been unemployed for 6-months or over.

The gross weekly pay for employees in Ipswich is lower than national and regional average and the Borough has higher numbers of people claiming benefits than county and national indicators suggest (2010).

The factors restricting economic growth in Suffolk in general are a lack of

qualified staff and poor broadband; as well as a lack of customers, transport links,

and poor quality premises (Suffolk Growth Strategy).

The economy in Ipswich needs to be diversified to broaden the economic base as the key economic sectors are identified primarily in the service sector, e.g. distribution, public administration, etc.

The good transport links in the Borough should be exploited as accessibility is a key issue when encouraging new residents.

There is a need to retain skilled workers and improve skills levels amongst the workforce.

There are opportunities to attract private sector interest in the town to service and provide more opportunities for existing and new communities, such as more and better shops to enhance the high street, and a focus on stalled developments.

Deprivation and Living Environment

Gainsborough, Whitton, Whitehouse, Gipping, Stoke Park, Priory Heath, Bridge and Alexander wards all have LSOAs in the bottom 20% most deprived nationally (Index of Multiple Deprivation).

Deprivation is a very complex issue and a number of different issues will need to be addressed for noticeable improvements to be realised.

30% of all the crime in Suffolk happens in Ipswich and 10% of all the crime in Suffolk happens in the Town Centre of Ipswich as a result of the night time economy. Ipswich also has the highest prevalence of organised crime in Suffolk including people trafficking, drug dealing and prostitution. Anti-social behaviour also forms a large percentage of crime incidents in Ipswich in June 2012. However, recorded crimes per 1000 of Ipswich's population have fallen from 106 in 2008-2009 to 77 in 2013-2014.

There is a need to tackle anti-social behaviour, and crime rates should be further reduced to enhance overall quality of life in Ipswich. This could be achieved through incorporating safety by design principles into new development and ensuring appropriate housing mixes are adopted. In addition, generally providing improved employment and educational opportunities for the local population could also contribute to improve crime rates.

Access to sports facilities should be enhanced. This could have associated health benefits.

Housing

Housing costs are relatively low but have gradually increased in recent years.

Median house price (July 2013) in Ipswich is £150,000, which shows an increase of 7.1% from the median price of the same time the previous year (£140,000). The average house price is lower than Suffolk (£167,000 in July 2013) and lower than that in the East of England (£178,000 August 2013 - ONS). House prices have gradually increased but incomes have not matched this rate of growth, which may lead to problems of housing affordability.

The affordability of purchased homes in 2011 was a ratio of 5:7 which was less than the affordability for Suffolk 6:9, the East of England 7:6 and England 6:5 (Office for National Statistics Local Profiles).

96 dwellings (net) were completed between 1st April 2012 and 31st March 2013, 7 of which were affordable housing completions (7.3%). 59 of these dwellings were on previously developed land (61.5%) and 17 were within the central IP-One area (17.7%). Gross housing completions (before calculating those dwellings lost) were 111 (AMR 2012-2013).

The number of housing completions has fallen from a peak in 2007/08 as a result of the recession and lower demand for flats in this period. Completions for 2012/13 were at the lowest level in Ipswich since 1998/99 when 60 dwellings were completed. Affordable housing completions vary from year to year influenced by the availability of funding available and Ipswich Borough Council has commenced a programme of affordable house building across the borough with 108 dwellings to be built on a site at Bader Close in east Ipswich in addition to 7 dwellings completed on Coltsfoot Road and Whitton Church Lane. The Council's adopted Core Strategy (2011) sets a target to allocate land to accommodate at least 14,000 additional residential units between 2001 and 2021 (700 dwellings p.a.). Housing delivery has averaged 653 p.a. April 2001 to March 2012. Completions peaked in 2007-08 but have fallen since then in line with the downturn and subsequent recession.

The Strategic Housing Marketing Assessment 2008 which has further been updated in 2012 found there is a need for smaller one to two bedroomed homes in Ipswich to meet the needs of smaller households and an ageing population, as well as a continued need for smaller two to three bedroomed family homes. Much of recent housing development in Ipswich, however, has been in the form of one and two bedroomed apartments and in the present economic climate there is an oversupply of flats.

There are 972 vacant homes in Ipswich (2014), a decrease from 1,750 in 2011/12.

2.9% of all dwellings in Ipswich were vacant in 2011/12, representing a decrease from 3.3% in 2010/11. This figure is slightly lower than the Suffolk and England average although slightly higher than the East of England average.

Housing regeneration efforts present a significant opportunity both to revitalise the housing stock, address deprivation and to improve quality of life.

Development within the Borough provides opportunities to meet housing needs, particularly for family housing and to counter balance the provision of flats within Ipswich town centre.

3.2.3 The SA Framework

Background to the SA Framework

The SA Framework underpins the assessment methodology and comprises a series of SA Objectives (covering social, economic and environmental issues) that are used to test the performance of the plan being assessed. Whilst the SEA Directive does not require the use of SA Objectives, they are a recognised tool for undertaking the assessment and are aspirations/goals that an authority/organisation should work towards achieving.

The SA Objectives are separate from the Core Strategy Objectives, although there may be some overlaps between them. The following section provides further details about the development of the SA Framework.

Development of the SA Objectives

The SA Objectives have been developed using the review of other relevant plans, programmes and environmental objectives, the baseline data and the key issues and opportunities. They were originally agreed in 2006 during the initial SA Scoping for Ipswich's Core Strategy. Twenty two SA Objectives were identified and the assessment showed that their compatibility with the twelve plan objectives was high with every sustainability objective having at least one plan objective positively compatible.

The SA Objectives have since been reviewed and modified to reflect the requirements of the new Core Strategy. Original SA Objectives ET8 and ET11 have since been merged, therefore there are 21 SA Objectives.

Table 3-3 presents the SA Objectives that were used in the assessment of the Core Strategy and its alternatives. Each of the SA Objectives is supported by a series of Sub-Objectives and indicators to add further clarity and to assist the assessment process. As the SA process progresses, indicators and where appropriate, targets were developed to assist the assessment.

Table 3-3 The SA Framework

SA Objective			SA Indicator	Source
ET1	To improve air quality	Would the policy contribute to the protection and improvement of local air quality? Would the policy contribute to the impact of traffic congestion on air quality?	ET1a. Number and distribution of AQMAs ET1b. Exceedances of the annual average objective level for Nitrogen Dioxide in the AQMAs	Air Quality Archive Ipswich Borough Council
ET2	To conserve soil resources and quality	Would any new developments protect the land within the Borough from new contamination and exposure to existing contaminated land? Would new developments help to maintain and enhance soil quality where possible?	ET2a. Area of contaminated land returned to beneficial use ET2b. Density of new development ET2c. Amount (ha) of previously developed land available	Ipswich Borough Council Office for National Statistics (ONS) Department for Communities and Local Government
ET3	To reduce waste	Would the implementation of the policy increase the proportion of waste recycling and re-use? Would the implementation of the policy reduce the production of waste per capita? Would the implementation of the policies result in reduction of the proportion of waste landfilled? Would new developments encourage a reduced demand for raw materials? Would new developments promote the use of recycled and secondary materials in construction?	ET3a. Tonnage of household waste produced and recycled ET3b. Location and number of waste facilities serving the Borough ET3c. Amount of household waste collected per household	Defra Suffolk County Council
ET4	To reduce the effects of traffic upon the environment	Would the policy ensure that public transport services meet people's needs i.e. through new bus services? Would the policy ensure that highways infrastructure meets people's needs (including walking and cycling routes)? Would new developments promote the use of sustainable travel modes and reduce dependence on the private car?	ET4a. Traffic volumes, access to local services and journeys taken by sustainable modes ET4b. Journey to work by mode	Ipswich Borough Council 2001 and 2011 Census
ET5	To improve access to key services for all sectors of the population	Would new development maintain and improve access to essential services and facilities? Would new development improve access to open space?	ET5a. Proportion of new developments with access to key services by walking, cycling and public transport ET5b. Number of LSOAs with wards in bottom 10% of most deprived in terms of barriers to housing and services provision	Ipswich Borough Council www.communities.gov.uk
ET6	To limit and adapt to climate change	Would new developments contribute to a reduction in greenhouse gas emissions? Would new developments require the inclusion of SuDS? Would new developments reduce the demand for energy and increase energy efficiency? Would new developments increase the use of renewable energy? Would the policy contribute to a reduction in CO₂ emissions from the transport sector? Would new developments reduce and manage flooding?	ET6a. Total CO₂ emissions for the Borough ET6b. Annual average domestic gas and electricity consumption ET6c. Provision of shading and greening (i.e. avoiding the heat island effect)	ONS Department for Energy and Climate Change (DECC) Ipswich Borough Council
ET7	To protect and enhance the quality of water features and resources and reduce the risk of flooding	Would the policy ensure the protection and enhancement of ground and surface water quality? Would the policy encourage sustainable use of water resources? Would the policy encourage the inclusion of flood mitigation measures such as SuDS? Would new developments reduce and manage flooding?	ET7a. Water quality in rivers and groundwater quality ET7b. Daily domestic water use (per capita consumption, litres) ET7c. Number of planning applications granted permission contrary to Environment Agency advice	The Environment Agency Suffolk County Council Ipswich Borough Council
ET8	To conserve and enhance biodiversity and geodiversity , including favourable conditions on SSSIs, SPAs and SACs	Would the policy protect and enhance designated sites of nature conservation importance? Would the policy protect and enhance wildlife especially rare and endangered species? Would new developments protect and enhance habitats and wildlife corridors? Would new developments provide opportunities for people to access wildlife and open green spaces? Would new development protect and enhance geodiversity?	ET8a. Area (ha) of woodland ET8b. Extent and condition of key habitats for which Biodiversity Action Plans have been established ET8c. Number and distribution of designated sites including SPAs, Ramsar sites, Sites of Special Scientific Interest, National Nature Reserves, Local Nature Reserves and County Wildlife Sites and Regionally Importance Geodiversity Sites in Ipswich ET8d. Percentage of designated sites in favourable condition	www.magic.gov.uk Suffolk Biodiversity Action Plan Natural England GeoSuffolk website SBRC
ET9	To conserve and enhance the historic environment, heritage assets and their settings	Would the policy protect and enhance heritage assets and their setting? Would the policy contribute to the protection and enhancement of historic landscape / townscape value?	ET9a. Number of heritage assets 'at risk' ET9b. Number of listed buildings reviewed annually for condition, repair and 'at risk' status.	English Heritage Ipswich Borough Council
ET10	To conserve and enhance the quality and local distinctiveness of landscapes and townscapes	Would new developments protect and enhance landscape character and quality? Would new developments protect and enhance townscape character and quality? Would new developments promote sensitive design in development? Would new developments promote local distinctiveness?	ET10a. Percentage of new housing completions achieving design standards such as Building for Life and Lifetime Homes	Ipswich Borough Council
HW1	To improve the health of those most in need	Would the implementation of the policy improve access to health and social care services? Would the policy contribute to a reduction in health inequalities amongst different groups in the community? Would new developments promote healthy lifestyles?	HW1a. Proportion of population with access to hospital / GP / Dentist HW1b. Proportion of journeys to work by foot or by bicycle HW1c. How children travel to school (Quality of Life Indicators (Government indicators) / Best Value Performance Indicators (Ipswich Borough Council) HW1d. Levels of physical activity data HW1e. Number of GP registrations for depression	Ipswich Borough Council 2001 and 2011 Census ONS
HW2	To improve the quality of life where people live and encourage community participation	Would new development encourage community participation? Would new development protect residential amenity from pollution? Would new developments minimise noise and light pollution?	HW2a. Play and open space quality, quantity and accessibility HW2b. Percentage of residents who are happy with their neighbourhood as a place to live (Place Survey) HW2c. Number of noise and light pollution complaints	Ipswich Borough Council Department for Communities and Local Government
ER1	To reduce poverty and social exclusion	Would the policy contribute to reduced overall levels of deprivation? Would the proposals benefit LSOAs that exhibit high levels of deprivation?'	ER1a. Proportion of population who live in wards that rank within the 10% most deprived in the country ER1b. Provision of childcare	www.communities.gov.uk Ipswich Borough Council / Suffolk County Council
ER2	To offer everybody the opportunity for rewarding and satisfying employment	Would the policy contribute to a reduction in unemployment in the areas most at need? Would new developments improve physical accessibility to jobs for those in greatest need? Would the policy ensure people are educated, trained and skilled to meet local economic needs? Would the policy ensure labour supply meets local economic needs?	ER2a. Working age unemployment ER2b. Employment by occupation ER2c. Youth unemployment data ER2d. Long term unemployment data ER2e. Average wage data	ONS / National Online Manpower Information System (NOMIS) Ipswich Borough Council www.communities.gov.uk
ER3	To help meet the housing requirements for the whole community	Would the policy ensure that there is sufficient housing to meet identified needs in all areas? Would new developments ensure that housing meets acceptable standards? Would new developments increase the availability of affordable housing?	ER3a. Number of new dwellings completed in Ipswich including affordable housing ER3b. Percentage split of dwelling types ER3c. Average house price ER3d. Number of people presenting themselves as homeless.	Suffolk Observatory ONS Ipswich Borough Council
ER4	To achieve sustainable levels of prosperity and economic growth throughout the plan area	Would the policy encourage new business formation? Would the policy increase and diversify employment opportunities? Would the policy encourage economic growth? Would the policy ensure sufficient land, buildings and premises are available to accommodate business start-up and growth? Would the policy ensure Infrastructure (including transportation) meets the needs of business?	ER4a. Planning consents for employment uses ER4b Take up of employment land ER4c Population in Employment	Ipswich Borough Council (Monitoring reports) ONS - Nomis www.nomisweb.co.uk
ER5	To support vital and viable town, district and local centres	Would new developments maintain and improve access to shops, services and facilities in centres? Would new developments ensure a mix of retail units in centres?	ER5a. No. / Percentage of vacant retail units ER5b. Commercial / retail rental data ER5c Percentage of new retail floorspace developed within defined centres.	Ipswich Borough Council www.communities.gov.uk
ER6	To encourage efficient patterns of movement in support of economic growth	Would the policy ensure sufficient land, buildings and premises are available to accommodate business start-up and growth? Would the policy ensure Infrastructure (including transportation) meets the needs of business? Would the policy ensure that public transport services meet people's needs i.e. through new bus services? Would the policy ensure that highways infrastructure meets people's needs (including walking and cycling routes)? Would the policy promote the use of sustainable travel modes and reduce dependence on the private car? Would the policy reduce the impact of traffic on the economy?	ER6a No. / percentage of people working from home ER6b Waiting times at junctions in Ipswich See also ET4a (employment land take up) and HW1b (journey to work)	Ipswich Borough Council Suffolk County Council
ER7	To encourage and accommodate both indigenous and inward investment	Would the policy encourage inward investment and new business formation? Would the policy support the preservation and / or development of a high quality built environment? Would the policy promote the development of multi-functional green infrastructure in urban areas? Would the policy enhance the reputation of urban areas as places to live, work and visit?	ER7a. Business start-ups and closures ER7b. No. of business enquiries to Ipswich Borough Council / Suffolk County Council by types and size of site ER7c. Employment land availability	Ipswich Borough Council Suffolk County Council
CL1	To maintain and improve access to education and skills for both young people and adults	Would new development increase levels of participation and attainment in education for all members of society? Would new development improve access to and involvement in lifelong learning opportunities? Would new developments improve the provision of education and training facilities?	CL1a. GCSE Attainment Levels (Grades A*-C) CL1b. Proportion of the population with no qualifications	ONS www.communities.gov.uk
CD1	To minimise potential opportunities for crime and anti-social activity	Would the policy contribute to a reduction in crime levels? Would the policy contribute to a reduction in the fear of crime? Would the policy contribute to a reduction in levels of anti-social behaviour? Would new developments encourage safety by design?	CD1a. Recorded crime per 1,000 population CD1b. Burglary Rate CD1c. Fear of Crime (Quality of Life, Suffolk Speaks, British Crime Survey) CD1d. Number of domestic noise complaints	ONS www.communities.gov.uk Ipswich Borough Council

3.2.4 Internal SA Objective Compatibility

The 21 SA Objectives have been tested against each other to identify any potential areas of internal incompatibility. The results are presented in Table 3-4 and summarised below.

Generally the SA Objectives were either compatible or no clear impacts between the objectives could be established. However, some uncertainties were identified. Compatibility was assessed as uncertain between SA Objective ER3 'To help meet the housing requirements for the whole community' and the following SA Objectives:

ET1: 'To improve air quality’
ET2: 'To conserve soil resources and quality’
ET3: 'To reduce waste’
ET4: 'To reduce the effects of traffic upon the environment’
ET6: 'To limit and adapt to climate change’
ET7: 'To protect and enhance the quality of water features and resources and reduce the risk of flooding’
ET8: 'To conserve and enhance biodiversity and geodiversity including favourable conditions on SSSIs, SPAs and SACs’
ET9:’To conserve and where appropriate enhance areas and sites of historical importance’
ET10: 'To conserve and enhance the quality and local distinctiveness of landscapes and townscapes’

Uncertainty was identified because new residential development has the potential to adversely affect biodiversity resources through direct land take, landscape and heritage resources through inappropriate siting and water resources through an increase in water demand / consumption. In addition, new residential development would also require the use of natural resources, raw materials and energy, and would increase pressure upon current waste management.

There could also be an increase of traffic during the construction / operation of new residential development associated with an increase of inhabitants and their future transport requirements therefore this could affect local air quality and climate change.

However, some of these uncertainties could be addressed through the DPD, by requiring developments to meet various standards e.g. Code for Sustainable Homes standards, promoting sustainable travel, and including measures to protect and enhance biodiversity. Table 3-4 uses the notations outlined below.

Objectives are compatible = + No clear impact on each other = 0

Mutually incompatible = - Compatibility unknown = ?

Table 3-4 Internal Compatibility of SA Objectives

	ET1	ET2	ET3	ET4	ET5	ET6	ET7	ET8	ET9	ET10	HW1	HW 2	ER1	ER2	ER3	ER4	ER5	ER6	ER7	CL1
ET1
ET2	0
ET3	+	+
ET4	+	+	0
ET5	+	?	0	+
ET6	+	+	+	+	?
ET7	0	+	+	+	0	+
ET8	+	+	+	+	0	+	+
ET9	0	0	0	0	0	0	0	+
ET10	+	+	+	+	0	+	+	+	+
HW1	+	0	0	0	+	0	0	0	0	0
HW2	0	0	+	+	+	0	+	+	+	+	+
ER1	0	0	0	0	+	0	0	+	+	+	+	+
ER2	0	0	0	0	+	0	0	0	0	0	0	0	+
ER3	?	?	?	?	0	?	?	?	?	?	0	+	+	+
ER4	0	0	0	0	+	0	0	0	0	0	0	+	+	+	+
ER5	0	0	0	0	+	0	0	0	+	0	0	+	+	+	+	+
ER6	+	+	0	0	+	+	0	+	0	0	0	+	+	+	+	+	+
ER7	0	0	0	+	+	+	+	0	0	0	0	0	+	+	+	+	0	+
CL1	0	0	0	+	+	0	0	0	0	0	0	+	+	0	+	+	0	0	0
CD1	0	0	0	0	+	0	0	0	0	0	0	+	+	+	0	+	+	0	0	+

3.2.5 SA Scoping Report Consultation

The SA process commenced in 2013 with the preparation of an SA Scoping Report for the Core Strategy Focused Review and the Site Allocations DPD (Hyder Report Reference: 5001-UA006314-UE31-01). The Scoping Report was in two parts - Part One covered the Core Strategy and Part Two, the Site Allocations DPD. The Scoping Report was issued to the Statutory Consultees, Natural England, English Heritage and the Environment Agency in October 2013 for comment. It was also published on the Councils website.

Following the identified need for a whole plan review rather than a focussed review of the Core Strategy a Scoping Letter was issued to Statutory Consultees and published on the Council's website in September 2014. The Scoping Letter provided an update to the change in scope since the 2013 Scoping Report.

Representations received have been addressed and taken on board in this SA Report. Representations received from the Scoping Letter along with how they were addressed are provided in Appendix C.

3.3 Stage B: Developing and Refining Options and Assessing Effects

3.3.1 Alternatives

As identified in Box 3, the SEA Directive requires that the assessment process considers alternatives:

Box 3: Consideration of Alternatives

"..an environmental report shall be prepared in which the likely significant effects on the environment of implementing the plan or programme, and reasonable alternatives taking into account the objectives and the geographical scope of the plan or programme, are identified, described and evaluated" (2001/42/EC) (Article 5.1).

The Practical Guide advises that only realistic and relevant alternatives should be considered and they should be sufficiently distinct to enable a meaningful comparison of their different environmental effects.

Identification of Reasonable Alternatives

Amount of Housing

The alternative scenarios for housing requirement projections are set out in the Topic Paper: Reviewing the Ipswich Housing Figures (January 2014) and relate to identifying a robust and realistic forecast of the likely number of new dwellings required. Alternative scenarios were investigated to apply different assumptions in relation to population change. These scenarios were Trend Migration, Low Migration, Household Constrained and East of England Forecasting Model. The Topic Paper outlines why the Trend Migration scenario is the most suitable to apply in determining the objectively assessed housing need for Ipswich Borough.

It is not appropriate to assess these scenarios through the SA process as their purpose is to arrive at the most likely nature and scale of future population change within the Borough. Identifying the likely sustainability effects of the different scenarios would not assist in this process of identifying need and therefore these alternatives are not intended to not be viewed in the same manner as alternative strategies identified as part of the SA process. This is reflected in the Planning Practice Guidance which states ' The assessment of development needs is an objective assessment of need based on facts and unbiased evidence. Plan makers should not apply constraints to the overall assessment of need, such as limitations imposed by the supply of land for new development, historic under performance, viability, infrastructure or environmental constraints. However, these considerations will need to be addressed when bringing evidence bases together to identify specific policies within development plans .' ^[5]

It should also be noted that a 'no plan' option i.e. continuation of the adopted CS2 has not been assessed as it is not considered to be a reasonable alternative (housing need has been updated).

Strategic Spatial Alternatives

The Topic Paper: Reviewing the Ipswich Housing Figures (January 2014) identified two alternative strategies for meeting the objectively assessed housing need.

Alternative strategy 1 in the Housing Topic Paper considers the potential for securing higher density development on housing sites to deliver a higher number of homes. Whilst it was concluded that this is unlikely to be deliverable at present due to economic conditions, this option could represent a realistic alternative in the longer term should economic conditions change. It would be an alternative to the proposed wording of policies CS2 and CS7 which states that the council will work with neighbouring local authorities to address housing need later in the plan period.

For the purposes of undertaking the SA, the residual need (minus windfalls) that would need to be met in neighbouring local authority areas is around 4,000 dwellings.

Alternative strategy 2 in the Housing Topic Paper put forward a further alternative whereby a greater amount of housing would be delivered outside of the Borough whilst the development at the Garden Suburb would reduce from 3,500 to 1,500. The development of the Garden Suburb is intended to come forward during the earlier stages of the plan period in acknowledgement that the release of all phases is necessary to secure the required infrastructure. It is not possible to instead rely on delivery in neighbouring local authority areas during this time as their currently adopted Core Strategies do not incorporate provision for meeting Ipswich's shortfall - this is an issue that would need to be addressed in the medium to long term through joint working between Ipswich Borough Council and the adjoining authorities. The conclusion that this alternative is not realistic therefore remains.

Consideration has also been given to the potential to release employment sites which have been allocated for some time but not been developed. However, of the two sites to which this applies one (IP147) is understood to be coming forward shortly and the other (made up of IP058, IP067 and IP099) is located adjacent to a sewage works and therefore not suitable for residential use. This option is therefore not considered to be realistic.

The development of sites identified in the SHLAA and the development of smaller sites (such as appropriate back gardens) is accounted for within the windfall figure at rates consistent with past delivery and the availability of deliverable sites (the latter of which has been assessed through the SHLAA). It is therefore not realistic to include an alternative which would see a greater amount of development from such sites.

In conclusion only alternative strategy 1 has been considered to be reasonable and is appraised in Section 4 and Appendix D as an alternative to the spatial strategy set out in CS2. The assessment of the alternative is appraised alongside proposed CS2 with commentary stating whether the alternative performs better or worse.

Policy Alternatives and Evolution

The Core Strategy and Development Management Policies have evolved since the 2011 Core Strategy and again since the 2013 Focussed Review ^[6]. Where significant changes have occurred, a commentary on the relative sustainability effects of these changes (and in effect alternative policy) is provided in Section 4 and Appendices D, E and F. It also considers the effects of not producing a policy in each case (NB for the Development Management Policies and some Core Strategy Policies this relates to the assessment undertaken in 2009).

3.3.2 Assessment of the Vision

Good practice guidance recommends that the key aims and principles of the plan should be assessed against the SA Objectives, in order to test their compatibility and to determine whether they accord with broad sustainability principles.

The Vision for the Core Strategy has been reviewed against the SA Objectives, and a summary of the key strengths, weaknesses and recommendations have been identified (as presented in Section 4.1). Recommendations were made to offset or alleviate any adverse impacts that were predicted, or to enhance any opportunities that were identified.

3.3.3 Assessment of the Strategic Objectives

Good practice guidance also recommends that the goals of a plan should be assessed against the SA Objectives.

The assessment of the twelve Strategic Objectives of the Core Strategy against the SA Objectives has been undertaken using a matrix based approach to determine their compatibility. Recommendations were suggested to offset or alleviate any potential sustainability conflicts between the Strategic Objectives and the SA Objectives. The assessment is presented in Section 4.2.

3.3.4 Appraisal of the Core Strategy Policies

The 20 Core Strategy Policies provide the strategic spatial approach to the development of Ipswich with ensuring the essential components 'live, work and play' are provided for. Infrastructure policies are also included as they support growth and development. The strategic spatial approach outlines the type, quantity and distribution of new development to 2031.

The Core Strategy Policies have been assessed in relevant groups against the SA Objectives to enable the identification of key strengths and weaknesses, and any potential areas for improvement. Mitigation measures and recommendations are suggested where relevant to offset or alleviate any predicted adverse impacts, or to enhance any opportunities that have been identified.

The assessment of the Core Strategy Policies has been undertaken using a matrix based approach. The assessment notations used in the assessment, together with their definition (i.e. how a positive score was assigned) are presented in Tables 3-5 and 3-6. When undertaking the assessment, the symbols assigned in the matrix were justified in the commentary box along with any uncertainties.

Table 3-5 Notations used in the SA

Major Positive Impact	The policy strongly supports the achievement of the SA Objective.	++
Positive Impact	The policy partially supports the achievement of the SA Objective.	+
Neutral/ No Impact	There is no clear relationship between the policy and / or the achievement of the SA Objective or the relationship is negligible.	0
Positive and negative outcomes	The policy has a combination of both positive and negative contributions to the achievement of the SA Objective, e.g. a short term negative impact but a longer term positive impact.	+/-
Uncertain outcome	It is not possible to determine the nature of the impact as there may be too many external factors that would influence the appraisal or the impact may depend heavily upon implementation at the local level. More information is required to assess the impacts.	?
Negative Impact	The policy partially detracts from the achievement of the SA Objective.	-
Major Negative Impact	The policy strongly detracts from the achievement of the SA Objective.	- -

Table 3-6 Temporal scale, Permanency and Certainty used in the SA

Long Term	Effects likely to arise in 10-25 years of Core Strategy implementation
Medium Term	Effects likely to arise in 5-10 years of Core Strategy implementation
Short Term	Effects likely to arise in 0-5 years of Core Strategy implementation
Direct	Direct effects.
Indirect	Indirect effects.
Reversible	Effects are reversible
Irreversible	Effects are irreversible
High/Medium/Low	High, medium or low certainty of prediction
Cumulative	Potential to have cumulative effect with other proposals or plans on this objective

A summary of the assessment of the Core Strategy Policies is provided in Section 4.3. The complete results of the assessment are presented in Appendix D.

3.3.5 Appraisal of the Development Management Policies

The Core Strategy contains 29 Development Management Policies designed to support the Core Strategy Policies and manage development in the borough.

The Development Management Policies have been assessed in groups against the SA Objectives using the technique described above for the assessment of the Core Strategy Policies. A summary of the assessment of the Development Management Policies is provided in Section 4.4. The complete results of the assessment are presented in Appendix E.

3.3.6 Appraisal of Cumulative and Synergistic Effects

The SEA Directive requires inter alia that cumulative effects should be considered. It stipulates consideration of "the likely significant effects on the environment…" and that " These effects should include secondary, cumulative, synergistic…effects" (Annex I).

The Practical Guide offers the following interpretation of terms:

Secondary or indirect effects comprise effects which do not occur as a direct result of the proposed activities, but as a result of complex causal pathway (which may not be predictable).

Cumulative effects arise from a combination of two or more effects, for instance, where several developments each have insignificant effects but together have a significant effect; or where several individual effects of the plan or programme have a combined effect.

All elements of the Core Strategy were taken into account within the cumulative assessment along with combined impacts as a result of other initiatives proposed within the borough. Cumulative and Secondary effects have been included in the SA where appropriate and Section 5 provides detail.

3.3.7 Appraisal of Transboundary Effects

The SEA Directive requires SAs to consider the transboundary effects of the plan on other EU member states. However, it is not considered likely that the Core Strategy could have significant effects upon other member states. Transboundary effects are mentioned within the SA where considered appropriate.

3.4 Stage C: Preparation of the SA Report (this stage)

This Interim SA Report presents the findings of the re-assessments to-date including the information collated in Stage A and during scoping, and documents the SA process so far. The results of the appraisal together with any mitigation measures proposed are recorded in the remaining chapters of this document.

3.5 Stage D: Consultation on the Core Strategy and the SA Report

This SA Report has now been issued for consultation alongside the Core Strategy Focused Review to all key stakeholders (including statutory consultees and the public) for comment under Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulation 2012. The consultation period will run from the 12th December 2014 to 5th March 2015. Following the close of the consultation period, Ipswich Borough Council intends to submit the Core Strategy and the SA for Examination. Any comments made in relation to the SA report will also be submitted as part of this process.

3.6 Stage E: Monitoring the significant effects of implementing the DPD

The activities relevant to monitoring that are stipulated in the SEA Directive are outlined below.

"Member States shall monitor the significant environmental effects of the implementation of plans and programmes... in order, inter alia, to identify at an early stage unforeseen adverse effects, and to be able to undertake appropriate remedial action" (Article 10.1).

The Environmental Report should provide information on "a description of the measures envisaged concerning monitoring" (Annex I (i)).

Based on the assessment conducted on the options and identification of potential significant environmental effects, a draft monitoring framework has been prepared and is presented in Section 6 of this report.

[1] Planning Practice Guidance 'Strategic environmental assessment and sustainability appraisal' 2014 and www.pas.gov.uk

[2] Reference ID: 11-016-20140306

[3] UK Sustainable Development Strategy: Securing the Future (2005) and the UK's Shared Framework for Sustainable Development, One Future - Different Paths (2005)

[4] Reference ID: 11-016-20140306

[5] Reference ID: 2a-004-20140306

[6] Assessments were only undertaken in the 2013 SA where there were judged to be significant differences between the adopted plan and the focused review draft policy.

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