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

(4) 4 APPRAISAL OF THE CORE STRATEGY AND ALTERNATIVES

(2) 4.1 The Vision

The vision is outlined in Section 2.

4.1.1 Sustainability Comments

A key theme of the vision is to promote and enhance sustainable transport within Ipswich. Due to the constrained nature of the Borough and the presence of four AQMAs this is a key issue that potentially could restrict growth. However, the vision seeks to implement traffic management measures in conjunction with improvements for pedestrians, cyclists and buses which will ensure effective links between Ipswich, the wider area and the town centre and contribute to keeping congestion down. All of which would benefit the SA Objectives related to air quality (ET1), climate change (ET6) and traffic movements (ET4).

With regards to the natural environment the vision seeks to ensure the Borough's network of beautiful parks, open spaces green infrastructure and open water is enhanced by new development along with ensuring the historic character of the borough is conserved and enhanced. This would particularly benefit SA Objectives ET8 'To conserve and enhance biodiversity and geodiversity, including favourable conditions on SSSIs, SPAs and SACs' and ET9 'To conserve and enhance the historic environment, heritage assets and their settings'

There is an emphasis placed upon the need to create a place 'where people aspire to live, work, learn, visit and invest' which would positively fulfil the social SA Objectives, as creating such a place would include improving housing, community and tourist facilities, employment opportunities, educational provision and would facilitate general regeneration.

The economic SA Objectives would be met through the vision's commitment to providing a concentration of accessible job opportunities within the town centre along with ensuring opportunities are created elsewhere including Futura Park. Providing employment opportunities along with housing provision would seek to promote sustainable economic growth.

4.1.2 Recommendations and Mitigation Potential

No recommendations or mitigation are proposed.

4.2 Strategic Objectives

The Core Strategy contains 12 Strategic Objectives to deliver the vision. The Strategic Objectives are presented on Section 2. Table 4-1 presents the compatibility of the Core Strategy Strategic Objectives against the SA Objectives.

Table 4-1 Compatibility of the SA Objectives and the Strategic Objectives

SA Objectives	Strategic Objectives
	1	2	3	4	5	6	7	8	9	10	11	12
ET1. To improve air quality		0	X			?	0			0	0	0
ET2. To conserve soil resources and quality		0		0		0	0		0	0	0	0
ET3. To reduce waste		0	X	0		0	0	0	0	0	0	0
ET4. To reduce the effects of traffic upon the environment		0	X		0	?	0	0		0	0
ET5. To improve access to key services for all sectors of the population		0			0		0	0			0	0
ET6. To limit and adapt to climate change			X	0		0	0	0	0	0	0	0
ET7. To protect and enhance the quality of water features and resources and reduce the risk of flooding			0	0		0		0	0	0	0	0
ET8. To conserve and enhance biodiversity and geodiversity , including favourable conditions on SSSIs, SPAs and SACs		0		0		0	0		0	0	0
ET9. To conserve and enhance the historic environment, heritage assets and their settings		0		0		0	0	0	0	0	0
ET10. To conserve and enhance the quality and local distinctiveness of landscapes and townscapes		0		0		0	0		0	0	0
HW1. To improve the health of those most in need		0	0	0			0				0	0
HW2. To improve the quality of life where people live and encourage community participation		0	0	0			0					0
ER1. To reduce poverty and social exclusion	0	0		0			0					0
ER2. To offer everybody the opportunity for rewarding and satisfying employment				0		0	0	0	0		0
ER3. To help meet the housing requirement s for the whole community				0	0			0	0	0	0
ER4. To achieve sustainable levels of prosperity and economic growth throughout the plan area				0				0	0	0	0
ER5. To support vital and viable town, district and local centres		0						0	0	0	0
ER6. To encourage efficient patterns of movement in support of economic growth			0		0	?	0	0		0	0
ER7. To encourage and accommodate both indigenous and inward investment	0	0	0	0				0	0	0	0
CL1. To maintain and improve access to education and skills for both young people and adults	0		0	0			0	0			0
CD1. To minimise potential opportunities for crime and antisocial activity	0	0	0	0	0	0	0		0			0

Key

= Objectives are compatible X = Objectives are potentially incompatible

0 = There is no link between objectives ? = The link between the objectives is uncertain

4.2.1 Sustainability Comments

Each of the Core Strategy Strategic Objectives were assessed against the SA Objectives in a compatibility matrix to determine their compatibility and to identify any potential areas where new Strategic Objectives need to be established or the existing ones clarified.

On the whole, the Strategic Objectives and the SA Objectives complement each other, with many positive correlations and only five potential incompatibilities recorded. The link between three Strategic Objectives and three SA Objectives was recorded as uncertain.

All five potential incompatibilities were related to Strategic Objective 3, which deals with the development of new housing and new employment sites. Concerns were related to traffic, air quality, waste, energy consumption and biodiversity. These issues however, are partially mitigated by the all-encompassing Strategic Objective 1, as it is taken that a commitment to sustainable and environmentally friendly development will aim to reduce traffic or limit its growth, reduce waste levels and increase recycling and reduce energy consumption (through low carbon or carbon-neutral developments with increased efficiency and/or use of renewable energy or CHP schemes) along with protecting biodiversity.

The three uncertainties are associated with Strategic Objective 6, transport. These all related to traffic and increased movements (and its effects i.e. poor air quality). This is because the Strategic Objective supports both improvements to sustainable transport and an increase in road capacity. This issue is mitigated to some extent by clearly stating support for improving public transport and cycling and walking facilities.

4.2.2 Recommendations and Mitigation Potential

No recommendations or mitigation are proposed.

(2) 4.3 Core Strategy Policies

The following sections present a summary of the SA of the strategic spatial approach outlined in the Core Strategy. The detailed assessment of the Core Strategy Policies is provided in Appendix D and details of how these have been incorporated within the Core Strategy are set out in a separate Annex produced by Ipswich Borough Council. The Core Strategy comprises 20 Core Strategy Policies which we have grouped to ease the assessment process. The groups comprise:

Spatial Strategy	Policy CS2: The Location and Nature of Development
Development of the Strategy	Policy CS1: Sustainable Development - Climate Change
	Policy CS3: IP-One Area Action Plan
	Policy CS4: Protecting our Assets
	Policy CS5: Improving Accessibility
	Policy CS6: The Ipswich Policy Area
Live	Policy CS7: The Amount of New Housing Required
	Policy CS8: The Balance Between houses and Flats
	Policy CS9: Previously Developed Land Target
	Policy CS10: Ipswich Garden Suburb (formerly Ipswich Northern Fringe)
	Policy CS11: Gypsy and Traveller Accommodation
	Policy CS12: Affordable Housing
Work	Policy CS13: Planning for Jobs Growth
	Policy CS14: Retail Development and Main Town Centre Uses
Learn	Policy CS15: Education Provision
Play	Policy CS16: Green Infrastructure, Sport and Recreation
Infrastructure	Policy CS17: Delivering Infrastructure
	Policy CS18: Strategic Flood Defence
	Policy CS19: Provision of Health Services
	Policy CS20: Key Transport Proposals

Each policy was assessed against a 'do nothing' option in the 2009 Sustainability Appraisal, with the exception of policies DM33 and DM34 which were not included in the Core Strategy at that time. A 'do nothing' option is however considered in below in relation to these policies.

4.3.1 Spatial Strategy (CS2)

Sustainability Comments

The policy seeks to focus the majority of new residential development and community facilities into the town centre, the Waterfront, Ipswich Village, and Ipswich Garden Suburb and into or within walking distance of the town's district centres. Later in the plan period the council will look to work with neighbouring authorities to deliver housing in the wider Ipswich housing market area.

This approach, on the whole, scored positively against the economic and social SA Objectives. This was because it promotes sustainable growth, development and regeneration across the borough to meet local needs but also places the highest densities in central areas (within IP-One and local centres) which are most accessible and most densely populated. It directs primary retail development towards the town centre and employment uses to existing, established employment areas, also providing a strategic employment site at Futura Park. There is a heavy focus on improving sustainable travel and access together with dispersing open space throughout the borough. These later points may have benefits to the health and wellbeing of the community. This approach also maximises the use of previously developed land within the central areas which are also the least sensitive in terms of their natural environments. However, the central areas contain a number of heritage assets including historic buildings. There is some uncertainty regarding the effects of development on the setting of these assets although the policy does specify that heritage assets and historic character should not be compromised. There are also large areas of Flood Zones 2 and 3 within the central areas (IP One) therefore new development has the potential to increase flood risk, although, it is appreciated that this issue is covered by specific flood policies elsewhere within the Core Strategy. It is recommended that these areas are not developed until the Ipswich Flood Defence Scheme is implemented.

Another key element of the spatial strategy is the delivery of a significant area of new residential and community uses within the Garden Suburb. This large greenfield site provides for a significant portion of Ipswich's housing needs and hence contributes strongly to this objective. It also seeks to ensure that local centres, amenities and the required infrastructure are also delivered. Nonetheless, this would result in the loss of one of the last remaining large greenfield areas within the borough and consequently this is reflected in the performance against a number of the environmental objectives including negative effects on the local landscape, soil, ground water quality/run-off and biodiversity. No designated areas would be affected by this and it should be possible to reduce the extent of adverse effects through mitigation and good design, notably through the provisions of the Garden Suburb SPD Interim Guidance (September 2014).

Overall the policy has a number of positive and negative scores against the environmental objectives to reflect the different aspects of the strategy as a whole. However, the increase in development is likely to increase the amount of waste produced and energy consumed. Carbon emissions are expected to increase although it is noted that elsewhere in the strategy there is a heavy emphasis on sustainable travel and sustainable building standards. The policy does not intent to propose development in areas that are covered by ecological designations. However, the proposals for the central urban areas and IP-One development are near to the Ramsar and SPA designations (also SSSI). It is not anticipated that the proposals would have likely significant effects on these areas directly although it will be important to consider the indirect effects of recreational pressure and undertake Habitats Regulations Assessment in conjunction with Natural England. This assessment is uncertain at this stage, however, it is important to note that this plan should be read as a whole and other policies (such as CS4 and DM31) would provide protection to these sites. The Appropriate Assessment ^[7] concluded no adverse effects upon the integrity of European sites from the Ipswich Borough Council Proposed Submission Core Strategy and Policies DPD Review alone or in combination with the Suffolk Coastal District Core Strategy and Policies.

The effects of the spatial strategy on air quality and traffic were appraised as overall negative with a medium to low certainty. This reflects the cumulative increase in development and likely trip generation particularly in central areas and the Garden Suburb site. However, it should be noted that the policy encourages the provision sustainable travel options and encourages development within the central areas which are already well served by sustainable transport and close to existing and proposed employment and amenities. The SA concludes that traffic is likely to increase overall although whether this may have a significant effect on congestion, air quality and the AQMAs is not certain. It recommends that updated traffic modelling is undertaken and that all future applications continue to thoroughly assess the cumulative effects of traffic and emissions and propose robust mitigation in line with other policies within the Core Strategy and the Garden Suburb SPD.

An element of uncertainty was also recorded with regard to the development of around 4,000 new dwellings in neighbouring authorities in the long-term. At this stage it is not known where these dwelling may be constructed although it is assumed that they would be close to the Ipswich boundary. As such it is not possible to say with any certainty what the effects on the SA Objectives would be, especially the environmental objectives which require a greater knowledge of location.

Mitigation / Enhancement Measures

The following mitigation / enhancement measures have been suggested to improve the sustainability performance of the policy:

• It will be essential for planning applications to thoroughly assess the impacts of traffic and air quality and to propose effective measures to mitigate any impacts following the guidance in the SPD, Policy CS5, Policy DM17 and the Travel Ipswich Scheme. Neighbouring authorities should also give significant consideration to this issue when allocating land to meet Ipswich's housing need.
• The policy may benefit from a specific reference to ensuring the public realm is of a high quality design along with new structures. However, it is noted that Design mitigation is provided in the Garden Suburb SPD, Policy DM5 and the Urban Character SPD.

Alternatives

As identified in Section 3.3.1, only one reasonable alternative to the spatial strategy has been identified. This considers the potential for securing higher density development on housing sites to deliver a higher number of homes. Assuming that in future years this would be economically viable, this would mean delivering an additional 4,000 homes on sites and through windfalls from 2020/21 onwards which are currently anticipated to deliver 5,175 homes. If the additional 4,000 were to be shared evenly amongst the sites this would lead to almost doubling the proposed densities. 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.

A detailed appraisal of the Alternative Strategy is provided alongside the Spatial Strategy in Appendix D. This concludes that providing for a higher density of new homes on the housing sites would generally perform negatively against the SA Objectives in terms of the following:

The alternative strategy provides for a higher density of new homes within the housing sites which may lead to greater traffic congestion and increased vehicular emissions compared with the preferred option as there would be a larger increase in population at each site therefore a higher concentration of vehicle use in each location.

In addition, providing higher density development may lead to greater adverse effects on biodiversity, heritage assets, soil resources and landscape / townscape character than proposed CS2 as there would be less scope to provide soft landscaping, urban greening, new green infrastructure, areas of open space or potential new Local Nature Reserves - all of which create opportunities to enhance the natural, built and historical landscape. It may also result in a less diverse housing mix with more flats and smaller homes which may mean that housing needs across the borough are not adequately met.

Finally higher density development within areas susceptible to flooding in Ipswich may exacerbate current issues as there would be a reduced scope to incorporate open space and SuDS measures into new development.

However, the alternative was judged to perform positively in relation to conserving soil resources, minimising emissions related to climate change and conserving biodiversity, landscapes and townscapes of neighbouring authority areas.

In all other respects the alternative would perform similarly to proposed CS2.

Having considered the assessments of the alternative and proposed CS2, it is concluded that on balance the proposed CS2 would provide greater sustainability benefits for the reasons outlined above and would also offer greater certainty in terms of deliverability should economic circumstances not create favourable conditions for higher density development in the future. Therefore the Alternative Strategy was not taken further in the development of the Core Strategy.

4.3.2 Development of the Strategy (CS1, CS3, CS4, CS5 and CS6)

Sustainability Comments

On the whole the policies scored positively against the SA Objectives.

CS1, CS4 and CS5 provide strong central policy for the Core Strategy as a whole by requiring a comprehensive approach to tackling climate change (through reducing energy use, carbon emissions and flood risk); conserving and enhancing the borough's built, historical, natural and geological assets; and, improving accessibility through the location of development, managing travel demand and encouraging sustainable transport measures.

The environmental SA Objectives scored particularly well against these policies. This was largely due to the focus of Policy CS4 on protecting assets and the contribution of CS1 and CS5 on helping to reduce carbon and air quality emissions.

CS3 promotes the development of an IP-One Area Action Plan which will allocate and define a range of regenerative measures in this area including Ipswich Village, the Waterfront, parking, an Education Quarter and built and natural environmental improvements. This policy reflects some of the benefits relating to a town centre focus within the spatial strategy (CS2) including the economic and social advantages to regeneration in this accessible area. Flood risk is a potential problem with much of the area within Flood Zone 2 or 3. This will be mitigated by the Ipswich Flood Defence Scheme once complete although it is recommended that development is phased to avoid flood risk areas until this time, as set out in CS18 with timescales for development identified in SP2 of the Site Allocations DPD. As per Policy CS2 there were also overall negative scores recorded for Policy CS3 against the SA Objectives associated with air quality, climate change and reducing the effects of transport on the environment. This was because it is likely that overall vehicle trips in this area will increase although whether this is likely to have a significant effect on air quality and the AQMAs is uncertain at this stage. It should also be noted that whilst overall negative effects were ascribed, Policy CS3 focusses a large proportion of housing development within the central urban area which could be seen as positive as the area contains the majority of amenities and jobs and is accessible by public transport.

Policy CS6 recognises the importance of joint working with neighbouring authorities to coordinate planning policies around the fringes of Ipswich. It is assumed that this will benefit the overall delivery of sustainable development in relation to a number of sustainability objectives.

Mitigation / Enhancement Measures

The following mitigation / enhancement measures have been suggested to improve the sustainability performance of the policies:

• It will be essential for planning applications to thoroughly assess the impacts of traffic and air quality and to propose effective measures to mitigate any impacts following the guidance within Policy CS5 and the Travel Ipswich Scheme.
• Policy CS4 could be strengthened though a direct reference in the policy wording to protecting and enhancing the boroughs soil resource and function.
• It is noted that there are overlaps between Policy CS4 and DM31. Nonetheless, there is considerable scope to expand Policy CS4 given its overarching nature at the front of the plan, in particular to protect and enhance the borough's designated natural assets including principally European, National and local level designations. A reiteration of the text in DM31 regarding protection of the European sites is recommended.
• Although it is not the purpose of Policy CS3 it should be ensured new development integrates well into the existing townscape, it is therefore recommended that a specific reference to this is included within CS3.

Alternatives

The consideration of 'do nothing' i.e.' no policy' was undertaken in the 2009 against Policies CS1, CS3, CS4, CS5 and CS6. In each case 'do nothing' performed worse against the SA Objectives than with a policy in place. This was because there would be fewer opportunities for providing control and direction, lower environmental standards and fewer opportunities for enhancement and regeneration.

There have been minor changes to Policy CS1 since the 2013 focussed review. This reflects changes in relation to the Council's carbon reduction target and reference to support Travel Ipswich's 15% modal shift is now included. However, the carbon reduction target was only relevant to the Council's own operations and therefore unlikely to significantly affect new development. The inclusion of the reference to support Travel Ipswich's 15% modal shift would help to reduce carbon emissions further in the borough and may benefit air quality, the AQMAs and health though encouraging people to walk / cycle rather than using their cars. Minor changes to Policies CS3, CS4, CS5 and CS6 are not considered to have made a significant difference to the SA.

4.3.3 Live (CS7, CS8, CS9, CS10, CS11 and CS12)

Sustainability Comments

These policies cover the amount and type of housing required including some locational direction in CS9 (Previously Developed Land) and CS10 (Ipswich Garden Suburb).

The amount of new housing required is set by the establishment of housing needs. This therefore performs strongly against the SA Objectives relating to housing need and other social and economic objectives. In essence the appraisal of policy CS7 also reflects the location of housing appraised in policy CS2. Similarly, policies CS8, CS11 and CS12 refer to the need to meet the needs of different groups and again perform strongly against SA Objective ' ER3. To help meet the housing requirements for the whole community'. CS11 stops short of identifying land for gypsy and traveller accommodation but provides guidance on site selection including minimising any adverse effects.

Policy CS9 encourages development to be on previously developed land first. This is a sustainable approach which is also more likely to avoid areas of ecological and landscape value.

Policy CS10 reiterates the role and structure of the Garden Suburb proposal including the range of uses proposed within it and the requirement to follow the Supplementary Planning Document which lays out clear principles for how the site should be developed including phasing and infrastructure provision. In essence the Garden Suburb has been appraised as part of CS2 and the scores relevant to the site are reflected here. In particular, the policy performs strongly in terms of meeting housing needs, access to services and a range of social benefits for the new residents. It is nonetheless a large greenfield development which is likely to affect the local landscape and a number of other environmental features, albeit it may be possible to reduce these through careful planning and mitigation. The Appropriate Assessment⁷ concluded no adverse effects upon the integrity of European sites from the Ipswich Borough Council Proposed Submission Core Strategy and Policies DPD Review alone or in combination with the Suffolk Coastal District Core Strategy and Policies.

As per the previous policy summaries, the 7,234 new homes to be developed in the borough would increase vehicle movements which may affect local air quality and potentially the four AQMAs although the significance of this is uncertain at this stage. In addition, the 4,051 to be delivered through working with neighbouring authorities may also affect air quality depending upon their location, although, without knowing where these could be located there is considerable uncertainty regarding this. However, a significant emphasis has been placed on promoting sustainable travel within the Core Strategy which should reduce this impact. This is reiterated in the Garden Suburb Supplementary Planning Document Interim Guidance (September 2014). At this stage overall negative effect have been ascribed to Policies CS7 and CS10 overall with regard to air quality and the effects of traffic on the environment.

Mitigation / Enhancement Measures

The following mitigation / enhancement measures have been suggested to improve the sustainability performance of the policies:

• It will be essential for planning applications to thoroughly assess the impacts of traffic and air quality and to propose effective measures to mitigate any impacts following the guidance in the Garden Suburb SPD, Policy CS5. Policy DM17 and the Travel Ipswich Scheme. Neighbouring authorities should also give significant consideration to this issue when allocating land to meet Ipswich's housing need.
• That said opportunities should be sought (particularly within Policy CS10) to encourage recycling within the new housing developments. Facilities should be provided to encourage reuse/recycling.
• Policy CS11 could be strengthened though removing the reference to conservation areas and historic sites in clauses ii and iii respectively and adding a new clause that states 'heritage assets'.

Alternatives

The consideration of 'do nothing' i.e. no policy was undertaken in the 2009 SA against Policies CS7, CS8, CS9, CS10, CS11 and CS12. In the case of CS8, CS9, CS10, CS11 and CS12 the 'do nothing' scenario performed worse against the SA Objectives than with the policies in place as without the policies housing mix would become unbalanced, developer led and there would unlikely be enough affordable family homes delivered. For Policy CS7 the 'do nothing' scored better against some of the environmental SA Objectives as no target in place would result in a lower number of homes being built - although it should be noted that housing need would not be met.

As relatively significant changes were proposed to CS7 and CS10 as part of the Draft Core Strategy Focused Review which was consulted on in early 2014, the SA considered an alternative 'do nothing' option which would mean relying upon the policies in the adopted 2011 Core Strategy. An alternative of a lower level of housing at the Garden Suburb was considered as part of the alternatives under CS2 (refer to section 4.3.1) although was not considered to be reasonable.

There have been minor changes to Policies CS7 and CS9 since the 2013 focussed review. Changes included updated housing targets and the removal of the 60% target for developing on previously developed land. The updates were due to previous targets no longer being considered reasonable alternatives especially with regard to the limited amount of previously developed land available in the Borough and the fact that housing numbers are based on an objectively assessed need. Changes to the other polices in this section, such as the removal of allocations for gypsy and traveller pitch provision in the Site Allocations DPD and amendments to the affordable housing targets are not considered to have made a significant difference to the SA.

4.3.4 Work (CS13 and CS14)

Sustainability Comments

Policies CS13 and CS14 seek to provide significant employment (including retail) opportunities (i.e. 12,500 new jobs) within the Borough. Therefore, the policies score very strongly against the economic SA Objectives. Together they would provide the foundations to improve existing high levels of income and employment deprivation, improve the vitality and viability of the Ipswich Central Shopping Area, encourage new business formation and encourage inward investment. This could have indirect benefits to a number of social objectives including encourage healthy lifestyles through focussing employment development within the accessible town centre which may help promote walking and cycling to work. CS14 seeks to promote retail and other town centre uses within the town centre. The principle of the growth of town centre uses in this area is reflected in the appraisal of the spatial strategy CS2.

The creation of new employment opportunities may also result in potentially negative environmental effects (e.g. increase in traffic, waste, energy, effects on biodiversity, townscape character, flooding etc) depending on the design of the site and its location. Those sites which are within areas of flood zone may also increase the risk of flooding and should not be developed until the Ipswich Flood Defence Scheme is operational as set out in CS18 and in policy SP2 of the Site Allocations DPD. Many sites are in central locations but others are spread across wider areas of the Borough. Scores in this case are largely both positive and negative which reflects the potential for such negative effects but also the ability for new employment sites to regenerate previously developed sites and to improve the character of some areas through mitigation and enhancement measures. The principles of this are reflected in the appraisal of CS2 including regarding traffic and air quality.

Mitigation / Enhancement Measures

The following mitigation / enhancement measures have been suggested to improve the sustainability performance of the policies:

• It will be essential for planning applications to thoroughly assess the impacts of traffic and air quality and to propose effective measures to mitigate any impacts following the guidance in the Garden Suburb SPD, Policy CS5. Policy DM17 and the Travel Ipswich Scheme.
• With regards to flooding, it should be ensured that the allocated 30ha (minimum) of new employment development (Policy CS13) is outside flood zones 2 and 3, which may mean waiting until the proposed flood defences are completed.
• It should be ensured that the 30ha (minimum) of new employment development (Policy CS13) is located away from statutory designated sites and is well integrated into the existing environment.

Alternatives

The consideration of 'do nothing' i.e. no policy was undertaken in the 2009 against Policies CS13 and CS14. In each case 'do nothing' performed worse against the SA Objectives than with a policy in place. This was because without the policies employment may not be focused within accessible locations i.e. out of town retail may be developed and fewer jobs may be created as there would be no targets.

There have been minor changes to Policy CS13 since the 2013 focussed review. The policy now plans for 12,500 jobs rather than 18,000 and provides for 10ha of development at Futura Park rather than16.7ha. This update was due to previous targets no longer being considered reasonable alternatives following a change in economic conditions.

Minor changes to Policy CS14 are not considered to have made a significant difference to the SA.

4.3.5 Learn(CS15)

Sustainability Comments

Policy CS15 seeks to ensure the provision of educational facilities in the Borough. Therefore largely positive scores were recorded against the social and economic policies, as providing educational facilities in accessible locations may encourage people to walk / cycle to school, would create construction jobs and elementary jobs, would help to support the vitality and viability of the centres and may even potentially attract businesses to locate near them.

Regarding the environmental SA Objectives, securing educational development on previously developed land such as the Suffolk New College and University Campus Suffolk would represent a positive use of land resources and may protect biodiversity resources. However, conversely educational development at the Garden Suburb would not represent a sustainable use of land resources as the site is greenfield and may adversely affect biodiversity resources. Effects on heritage assets were assessed as uncertain as it would depend upon where educational development was specifically located, this may also be true for landscape / townscape character, however, ensuring high quality design that complements and enhances the character and quality of the local townscape would mitigate against any adverse effects.

Mitigation / Enhancement Measures

The following mitigation / enhancement measures have been suggested to improve the sustainability performance of the policy:

• It is recommended that the policy should include a link to the Travel Ipswich scheme.

Alternatives

The consideration of 'do nothing' i.e. no policy was undertaken in the 2009 against Policy CS15. The 'do nothing' performed worse against the SA Objectives than with the policy in place. This was because there would be no guidance in place to support educational provision to meet local need.

There have been minor changes to Policy CS15 since the 2013 focussed review i.e. the removal of support for a new 14 - 19 centre outside the borough, however, this and other changes are not considered to have made a significant difference to the SA scores on the whole.

4.3.6 Play(CS16)

Sustainability Comments

Policy CS16 seeks to enhance and extend the ecological network, green corridors and open spaces across Ipswich. Therefore, positive scores were recorded against many of the environmental SA Objectives. This was because policy would help to protect and conserve biodiversity resources, maintain soil quality, reduce effects of traffic upon the environment by encouraging more sustainable movement across networks, protect designated sites and conserve and enhance the quality and local distinctiveness of landscapes and townscapes.

Positive scores were also recorded against the social SA Objectives as the policy may contribute to encouraging healthy lifestyles through the provision of safe and freely accessible open spaces, sport and recreational facilities. It would also help to protect residents from amenity pollution and noise and light pollution which would contribute towards improving the quality of life where people live.

The scores against the economic SA Objectives were largely neutral, however, providing green spaces in accessible locations may help to improve access to shops, services and facilities across the borough and may help to improve the image and reputation of local areas as places to live, work and visit.

Mitigation / Enhancement Measures

No mitigation or enhancement measures were suggested to improve the sustainability performance of the policies.

Alternatives

The consideration of 'do nothing' i.e. no policy was undertaken in the 2009 SA against Policy CS16. The 'do nothing' option performed worse against the SA Objectives than with the policy in place. This was because there would be no guidance in place to support the provision of green infrastructure, sport and recreation facilities that benefit health and wellbeing along with providing many environmental benefits such as new habitats, flood storage and positive effects on townscape/ landscape character and quality.

There have been minor changes to Policy CS16 since the 2013 focussed review including support for the provision of an extension to the Orwell Country Park and potentially a visitor centre - subject to effects on the SPA. This would provide greater opportunities for recreation and healthy lifestyles and may enhance the image of Ipswich as a place people want to visit.

4.3.7 Infrastructure(CS17, CS18, CS19 and CS20)

Sustainability Comments

Policies CS17, CS18, CS19 and CS20 collectively seek to ensure infrastructure needs associated with new development are met. Therefore largely positive and neutral effects were recorded across the social, environmental and economic SA Objectives. Adequate infrastructure would help to relieve congestion at key routes of the Borough and the requirement for funding for off-site measures could help to address wider road capacity and congestion issues and thus result in improved air quality in the long term. The policies also seek to improve access to open space, school and health facilities and play areas in addition to providing new areas - this would also have health benefits and may enhance quality of life. CS18 would create major benefits in terms of reducing the risk of flooding through the support to implement the Ipswich Flood Defence Management Strategy.

Policies CS17, CS18, and CS20 would also all encourage sustainable economic growth though their commitment to provide key infrastructure thus facilitating new business formation and meeting the needs of business through improved access. In addition, town centre enhancements and enhanced pedestrian environment at the Waterfront may attract more visitors which will support the local economy.

Mitigation / Enhancement Measures

No mitigation or enhancement measures were suggested to improve the sustainability performance of the policy.

Alternatives

The consideration of 'do nothing' i.e. no policy was undertaken in the 2009 against Policies CS17 (this was also re-assessed in 2013), CS18, CS19 and CS20. The 'do nothing' performed worse against the SA Objectives than with the policies in place. This was because there would be fewer opportunities for providing control and direction, lower environmental standards (i.e. less emphasis on avoiding development in flood zones) and fewer opportunities for the enhancement of infrastructure and facilities provision. However, it should be noted that even without these policies in place, other measures such as national planning policy guidance and the role of statutory regulators would still be enforced.

There have been minor changes to CS20 since the 2013 focussed review. Policy CS20 no longer includes reference to the 'Bacon Chord', however, this is because the project has now been completed. Minor changes to other policies are not considered to have made a significant difference to the SA.

4.4 Development Management Policies

The following sections present a summary of the SA of the development management policies outlined in the Core Strategy. The detailed assessment of the development management policies is provided in Appendix E. The Core Strategy comprises 29 Development Management Policies which we have grouped to ease the assessment process. The groups comprise:

Sustainable Development, Flooding and Sustainable Drainage	Policy DM1: Sustainable Design and Construction
	Policy DM2: Decentralised Renewable or Low Carbon Energy
	Policy DM3: Provision of Private Outdoor Amenity Space in New and Existing Developments
	Policy DM4: Development and Flood Risk
Urban Design Policies and Protecting Our Assets	Policy DM5: Design and Character
	Policy DM6: Tall Buildings
	Policy DM8: Heritage Assets and Conservation
	Policy DM9: Buildings of Townscape Interest
	Policy DM10: Protection of Trees and Hedgerows
Small Scale Residential Development, Small Scale Infill and Backland Residential Development, Subdivision of Family Dwellings, Affordable Housing and the Density of Residential Development	Policy DM12: Extensions to Dwellinghouses and the Provision of Ancillary Buildings
	Policy DM13: Small Scale Infill and Backland Residential Developments
	Policy DM14: The Sub-division of Family Dwellings
	Policy DM24: Affordable Housing
	Policy DM30: The Density of Residential Development
Transport and Access	Policy DM17: Transport and Access in New Developments
	Policy DM18: Car and Cycle Parking
Proposals in Retail Areas	Policy DM20: The Central Shopping Area
	Policy DM21: District and Local Centres
	Policy DM22: Town Centre Uses Outside the Central Shopping Area
	Policy DM23: Retail Proposals Outside Defined Centres
Employment Land	Policy DM25: Protection of Employment Land
Amenity, Open Space, Sport and Recreation and Community Facilities	Policy DM26: Protection of Amenity
	Policy DM27: Non-residential Uses in Residential Areas
	Policy DM28: Protection of Open Spaces, Sport and Recreation Facilities
	Policy DM29: Provision of New Open Spaces, Sport and Recreation Facilities
	Policy DM32: Protection and Provision of Community Facilities
The Natural Environment	Policy DM31: The Natural Environment
	Policy DM33: Green Corridors
	Policy DM34: Countryside

4.4.1 Sustainable Development, Flooding and Sustainable Drainage (DM1, DM2, DM3 and DM4)

Sustainability Comments

The policies generally scored positively against the SA Objectives. This was largely due to the nature of the policies seeking to promote sustainable development. There were, however, uncertainties recorded against Policy DM2 'Decentralised Renewable or Low Carbon Energy' and the SA Objectives associated with biodiversity, heritage assets and landscape. This was because renewable and low carbon energy schemes have the potential to impact on the setting of heritage assets, change landscape character and adversely affect biodiversity (particularly birds and bats with regards to wind turbines). As the location of such development is unknown, effects were deemed uncertain. Policy DM4 scored well against the environmental SA Objectives ET6 'To limit and adapt to climate change' and ET7 ' To protect and enhance the quality of water features and resources and reduce the risk of flooding' as it ensures new development does not exacerbate current flooding in the borough along with providing SuDs measures where appropriate. Policy DM4 also ensures water efficiency measures are maximised in new development.

The scores against the social and economic SA Objectives were largely neutral with some positives. This was due to the limited effects the policies could lead to. Positive scores were associated with ensuring new development is highly accessible to existing facilities, including health facilities and through committing to a minimum BREEAM standard which may help to encourage investment (the provision of sustainable offices). Also, ensuring development achieves a minimum Level 4 of the Code for Sustainable homes and conversions achieve a minimum BREEAM Domestic Refurbishment 'Very Good', may contribute to improving housing stock which could reduce high levels of living environment deprivation within the borough.

Mitigation / Enhancement Measures

The following mitigation / enhancement measure has been suggested to improve the sustainability performance of the policies:

• It is recommended that Policy DM2 includes reference to the need for any new energy sources to be fully assessed for their effects on the natural and built environment and local amenity. Proposals should only be allowed where they do not incur significant adverse effects.

Alternatives

The consideration of 'do nothing' i.e. no policy was undertaken in the 2009 SA against the policies. In each case 'do nothing' performed worse against the SA Objectives than with a policy in place. This was because there would be fewer opportunities for providing direction to encourage sustainable development or encouraging private amenity space and lower environmental standards i.e. less guidance to ensure development does not occur in flood zones. However, note that other national policy measures and the role of the Environment Agency would still apply.

There have been minor changes to Policy DM1 since the 2013 focussed review. The policy now requires lower Code for Sustainable Homes and BREEAM standards. Although standards have been reduced in the updated policy, a high standard is still required, however, the standards required are now more viable, achievable and deliverable so may result in more developers meeting the requirements albeit at a cost of slightly lower standards. Minor changes to Policies DM2, DM3 and DM4 are not considered to have made a significant difference to the SA scores.

4.4.2 Urban Design Policies and Protecting Our Assets (DM5, DM6, DM8, DM9 and DM10)

Sustainability Comments

The policies collectively seek to ensure high quality design whilst protecting the Borough's built and natural assets. Therefore, the policies scored well against the environmental SA Objectives. Policies DM5, DM6, DM8 and DM9 all benefit landscape / townscape / heritage through their commitment to retaining buildings of townscape interest, ensuring tall buildings do not have adverse effects on the setting of Conservation Areas and promoting high quality design, all of which would help to protect the character of the urban areas. Policy DM9 supports protection, retention and repair buildings judged to be of local townscape interest, particularly those with no other statutory protection. Policy DM10 commits to providing and protecting urban greening - this would benefit local townscape along with, providing biodiversity and air quality benefits.

Effects against the social and economic SA Objectives were largely neutral with some positive scores. Under DM5, positive scores were related to promoting mixed use developments and neighbourhoods. This could lead to a reduced need to travel and improved access to key local services such as GPs, dentists etc. In addition, requiring new layouts and designs to be orientated towards cyclists and pedestrians could promote healthier and more sustainable forms of transport in Ipswich and help combat conditions such as obesity and its related health conditions. It should also be noted that improving the built environment in Ipswich over time may also encourage and accommodate both indigenous and inward investment.

Mitigation / Enhancement Measures

The following mitigation / enhancement measure has been suggested to improve the sustainability performance of the policies:

• Policy DM10 may benefit further through including a reference to the Hedgerow Regulations 1997 which protect 'important hedgerows' from being removed (uprooted or destroyed).

Alternatives

The consideration of 'do nothing' i.e. no policy was undertaken in the 2009 against the policies. In each case 'do nothing' performed worse against the SA Objectives than with a policy in place. This was because there would be fewer opportunities for providing control or opportunities for enhancement of the built environment in Ipswich.

There have been minor changes to Policy DM8 since the 2013 focussed review. The policy has now been expanded to protect not only Conservation Areas but other heritage assets in Ipswich. Therefore the policy provides greater protection of the historic environment and heritage assets. Minor changes to other policies are not considered to have made a significant difference to the SA.

4.4.3 Small Scale Residential Development, Small Scale Infill and Backland Residential Development, Subdivision of Family Dwellings, Affordable Housing and the Density of Residential Development (DM12, DM13, DM14, DM24 and DM30)

Sustainability Comments

The policies seek to manage small infill development, extensions, the sub-division of family homes, the provision of affordable housing and the density of new development (i.e. high within the town centre an lower elsewhere). All of which scored well against the social SA Objectives as they seek to ensure there is the right mix of new homes to meet local needs. The policies were also deemed to have health benefits as they would ultimately improve housing stock.

It should be noted that the principle and general location of new homes within the Borough was assessed within Policies CS2 and CS7. Therefore the assessment of Policies DM12, DM13, DM14 and DM30 focussed on the details relating to the type and make up of new housing. For this reason effects on the environment were limited. Although, effects against the environmental SA Objectives on the whole were recorded as positive and negative against Policy DM30 'the density of residential development'. This was because locating higher density homes within the town centre would mean more homes may be located in flood zones, may increase vehicle travel in an area with four AQMAs and may adversely affect the setting of heritage assets. However, there are a far fewer biodiverse spaces in town centre where high density development is proposed, the policies propose densities that are more appropriate to the existing townscape character, and propose higher densities of homes in more accessible locations.

Effects against the economic SA Objectives on the whole were recorded as neutral, although it is worth noting that higher density development within the town centre would ensure homes are close to amenities, jobs and transport hubs.

Mitigation / Enhancement Measures

The following mitigation / enhancement measure has been suggested to improve the sustainability performance of the policies:

• For Policy DM13, the loss of green space should be resisted where it would result in a significant loss of vegetation, trees etc that support valuable habitats.

Alternatives

The consideration of 'do nothing' i.e. no policy was undertaken in the 2009 SA against the policies. In each case 'do nothing' performed worse against the SA Objectives than with a policy in place. This was because without the policies there may become an imbalance in housing mix which does not meet local need. In addition, there may be less control over developing in gardens and extensions to existing homes which may lead to lower environmental standards.

There have been minor changes to Policies DM12, DM13, DM14, DM24 and DM30 since the 2013 focussed review, however, they are not considered to have made a significant difference to the SA.

4.4.4 Transport and Access (DM17 and DM18)

Sustainability Comments

Together the policies ensure that transport and access provision is incorporated into new development that promotes sustainable traffic patterns in Ipswich. Policy DM17 states that to promote sustainable growth in Ipswich and reduce the impact of traffic congestion, new development shall not result in a significant adverse impact on rights of way or the local road network in respect of traffic capacity, highway safety, air quality or the four AQMAs. Therefore a number of positive effects were recorded against the SA Objectives relating to air quality, climate change, access, promoting sustainable transport and health. In addition, improvements to transport and access may over the long term support vital and viable town, district and local centres through improved accessibility. This would also be supported through improved cycle parking provision across the Borough and limited parking within the town centre.

Mitigation / Enhancement Measures

No mitigation or enhancement measures were suggested to improve the sustainability performance of the policies.

Alternatives

The consideration of 'do nothing' i.e. no policy was undertaken in the 2009 SA against the policies. In each case 'do nothing' performed worse against the SA Objectives than with a policy in place. This was because there would be fewer opportunities for providing control and direction for sustainable transport. Over time there would be an increase in private car use and greater adverse effects on air quality and the AQMAs.

There have been minor changes to Policies DM17 and DM18 since the 2013 focussed review, however, they are not considered to have made a significant difference to the SA.

4.4.5 Proposals in Retail Areas (DM20, DM21, DM22 and DM23)

Sustainability Comments

The policies collectively seek to focus retail development within a defined area, to retain and provide local shops and community facilities within defined District and Local Centres, to provide leisure, recreation, culture and tourism uses within the IP-One Area but outside the Central Shopping Area and to manage retail development outside defined District and Local Centres. Therefore, on the whole the policies performed well against the SA Objectives that seek to improve access, support vital and viable town centres, promote sustainable levels of prosperity and economic growth and encourage inward investment - as the policies together seek to focus appropriate retail and commercial development within defined boundaries and deter inappropriate use.

Mitigation / Enhancement Measures

No mitigation or enhancement measures were suggested to improve the sustainability performance of the policies.

Alternatives

The consideration of 'do nothing' i.e. no policy was undertaken in the 2009 SA against the policies. In each case 'do nothing' performed worse against the SA Objectives than with a policy in place. This was because there would be fewer opportunities for providing control and direction for retail development. Without the policies in place this could lead to more out of town retail units which are not accessible or meet local need.

There have been minor changes to Policies DM20, DM21, DM22 and DM23 since the 2013 focussed review, however, they are not considered to have made a significant difference to the SA.

4.4.6 Employment Land (DM25)

Sustainability Comments

The policy seeks to safeguard employment land within existing and allocated employment sites in Ipswich. Therefore, effects against the economic and social SA Objectives were largely assessed as positive as safeguarding employment areas in accessible locations may offer opportunities for new jobs over the medium to long term, may encourage new business formation, would support district and local centres and may and diversify employment opportunities.

Effects against the environmental SA Objectives exhibited more negative effects and uncertainties. Policy DM25, may lead to an increase in vehicle movements related to people accessing employment which may negatively impact air quality, the AQMAs, carbon emissions and the effects of transport on the environment although there is some uncertainty over whether this is significant or not. However, the clustering of employment areas within accessible locations may indirectly encourage people to access employment via sustainable modes of transport. Effects on waste and flood risk were assessed as negative as the policy may over the long term increase waste production and increase flood risk within the IP One Area,.

Mitigation / Enhancement Measures

The following mitigation / enhancement measure has been suggested to improve the sustainability performance of the policies:

• Effects on water quality / pollution could be mitigated using standard, accepted mechanisms such as the Environment Agency's Pollution Prevention Guidelines.

Alternatives

The consideration of 'do nothing' i.e. no policy, was undertaken in the 2009 SA. The 'do nothing' option performed worse against the SA Objectives than with a policy in place. This was because there would be no safeguarding of existing employment sites which may lead to ad hoc employment development across the borough and potentially insufficient employment land coming forward.

There have been minor changes to Policy DM25 since the 2013 focussed review. The policy now includes a list of existing employment areas within the borough which should be safeguarded throughout the plan period. Therefore the policy now provides a greater protection to existing employment sites though this specific reference.

4.4.7 Amenity, Open Space, Sport and Recreation and Community Facilities (DM26, DM27, DM28, DM29 and DM32)

Sustainability Comments

The policies seek to protect the amenity of Ipswich's residents, manage non-residential use in residential areas, protect and provide open space, sport, and recreational facilities and protect and provide community facilities to meet local need.

Effects against the environmental SA Objectives were on the whole positive as protecting and providing open space would protect soil resources, may provide new habitats for wildlife, may provide flood storage and provide urban greening which may benefit townscape character.

Effects against the social SA Objectives were also largely beneficial as the policies seek to protect and increase the provision of open space, recreational facilities and opportunities for sport which would contribute to promoting healthy lifestyles across the borough. In addition, Policies DM25 and DM26 specifically seek to guard against adverse effects on amenity resulting from new development. They seek to do this by refusing development that would cause a material nuisance (i.e. through noise, light pollution etc.) and where it would be detrimental to human health, therefore effects were recorded as positive.

The policies against the economic SA Objectives were on the whole neutral. However, the commitment to the protection and provision of community facilities to meet local need may contributing to ensuring district and local centres are viable.

Mitigation / Enhancement Measures

No mitigation or enhancement measures were suggested to improve the sustainability performance of the policies.

Alternatives

The consideration of 'do nothing' i.e. no policy was undertaken in the 2009 SA against the policies. In each case 'do nothing' performed worse against the SA Objectives than with a policy in place. This was because there would be fewer opportunities for providing control and direction and fewer opportunities for the enhancement and provision of open and amenity space. In addition the provision of community facilities to meet local needs may not be realised.

There have been minor changes to Policies DM26, DM27, DM28, DM29 and DM32 since the 2013 focussed review, however, they are not considered to have made a significant difference to the SA scores.

4.4.8 The Natural Environment (DM31, DM33 and DM34)

Sustainability Comments

The policies seek to guard the natural environment (including European sites and the countryside) against inappropriate development and provide and enhance green corridors.

Due to the nature of the policies many positive scores were recorded against the environmental SA Objectives. Policy DM31 specifically commits to protecting and enhancing biodiversity across the borough, from European sites and SSSIs to County Wildlife Sites, Local Wildlife Sites and sites important for their geodiversity. It also makes specific provision for the protection of European sites that mirrors the Habitats Directive. In addition, to establishing an ecological network across the borough all of which would benefit local wildlife along with helping to facilitate its movement throughout the borough. Policy DM34 would also benefit soil resources through its commitment to retaining the best and most versatile agricultural land. Positive effects were also recorded against the SA Objectives that protect and enhance the quality of water features and conserve and enhance local landscapes and townscapes.

There may be health benefits associated with the policies as the establishment of attractive green corridors and ecological networks that connect the borough along with improving links to open spaces / the countryside may encourage people walk / cycle which in turn may encourage healthy lifestyle choices and benefit mental wellbeing.

Effects against the economic Objectives on the whole were neutral. However, the development of multi-functional green infrastructure in urban areas may contribute to making urban Ipswich an attractive place people may want to invest in.

Mitigation / Enhancement Measures

The following mitigation / enhancement measure has been suggested to improve the sustainability performance of the policies:

• Policy DM31 could be strengthened through making reference to 'alone or in-combination with other proposals'.

Alternatives

The 'do nothing' option, i.e. no policy instead of DM31, DM33 and DM34 would perform worse against the SA Objectives than with the policies in place. This is because there would be less protection afforded to protecting the natural environment, providing and protecting green corridors and guarding the countryside from inappropriate assessment.

There have been significant changes to Policy DM31 since the 2013 focussed review. The policy now affords protection to the whole natural environment rather than local natural and geological interest. This would therefore help to improve the performance of the policy against the environmental SA Objectives and clarifies the protection afforded to European site. Policies DM33 and DM34 were not previously included within 2013 focussed review, therefore a comparison cannot be made.

[7] The Appropriate Assessment report relates to assessment under the Habitats Directive and is available as a separate report.