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

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(2) Appendix C

Consultation Comments

Comments on Core Strategy Interim Sustainability Appraisal Report (December 2013)

Summary of Response

Respondent

Council’s comments

Action required

Largely in agreement with the findings of the sustainability appraisal report and have no specific or general comments to make.

Environment Agency

Noted

None

The National Planning Policy Framework states that broad locations can be identified for development late in the plan period, but the broad location of ‘Ipswich Policy Area’ (IPA) provides no clarity as to the proportion of dwellings expected to be provided in each neighbouring authority. The sustainability appraisal (SA) does not provide any assessment of broad locations or cumulative effects on areas with known constraints. In light of the limited land available in Ipswich the SA should consider all reasonable alternatives e.g. increasing densities, and consider the plans already adopted by neighbouring authorities and developments in the IPA already established in principle.

Suffolk Coastal District Council

It is agreed that the Sustainability Appraisal should consider the potential effects of the longer term policy of working with neighbouring authorities however at this stage it is not possible/appropriate to identify broad locations outside Ipswich Borough as the plan relates to Ipswich Borough only. Whilst higher densities are understood to be unviable at this point in time, there may be scope to develop higher density development in the Borough in the future and therefore this could be considered as a strategic alternative. Developments occurring/allocated in the IPA area outside Ipswich at the moment could not be counted against both the Ipswich housing need and the housing need of neighbouring authorities.

The Sustainability Appraisal has been revisited in order to consider the effects of working with neighbouring authorities to meet housing need later in the plan period and to consider the strategic alternative of higher density development within Ipswich.

Would advise that reference is made to the requirement for a Habitats Regulation Assessment to assess proposals on Ramsar sites. The SA should adopt a topic based approach in assessing the effects of the plan on the environment and locally designated sites such as County Wildlife Sites. Connections between topics should be considered. The report should reference Suffolk Biodiversity Action Plan, local Green Infrastructure Plan, Natural England’s ‘standards for accessible natural greenspace’ (ANGst), and Analysis of Accessible Natural Greenspace Provision for Suffolk, the local Water Cycle Study and Sustainable Drainage Systems (SuDS).

Private individual

It is agreed that the requirements for HRA should be within the policies. It is also agreed that further detail should be included in DM31 in relation to the categories of designated sites.

Policy DM31 has been amended to refer to the requirements of the Habitats Directive and to contain specific policy for different designated sites.

Additional text on open spaces, green infrastructure, improved ecological networks and tree canopy cover are supported (Para. 4.2.1).

Northern Fringe Protection Group

Noted

None

SA fails to see the implications of changes to the Core Strategy; the removal of any Previously Developed Land target is a major change. Development of the greenfield Garden Suburb will reduce development of brownfield sites which should be a priority. A suburb creates more traffic than sites near to existing employment and will therefore impact upon environmental objectives. A specific target for jobs in Ipswich not the Policy Area is also required in order to have any meaning. The implications in switching from a jobs led to a housing led strategy are huge and must be assessed.

Northern Fringe Protection Group

Appendix C of the Strategic Environmental Assessment and Sustainability Appraisal of the Focused Review of the Core Strategy and Policies Development Plan Document (Hyder, December 2013) outlines the implications of the change to the Policy CS9.

Policy CS13 relates to the creation of in the region of 12,500 jobs in Ipswich Borough.

The 2013 Sustainability Appraisal (reference above) has considered the changes between adopted CS13 and the proposed revisions to CS13.

None

The Sustainability Appraisal / Strategic Environmental Assessment process requires an examination of the baseline information of the Borough as it is now together with data on how it may change in the future. The Core Strategy and SA must therefore be based on the best data available, which is not the case as it fails to utilise the most recent DCLG or East of England Forecasting Model 2013 forecasts.

Northern Fringe Protection Group

The SA baseline, set out in the Scoping Report, identifies the current situation whereas the East of England Forecasting projects future jobs growth which has informed policy CS13. The assessment of adopted policies represents the assessment of likely direction of change without the review of the plan (i.e. the ‘no plan’ alternative), as detailed in Section 3 and Appendix E of the 2013 Interim SA Report.

None

SA must take account of new governmental guidance on the National Planning Policy Framework issued following the Ministerial Statement of 6th March 2014. Changes include: issuing guidance on flood risk; clarifying that local plans can be sound where authorities cannot identify housing land for years 11-15; allowing windfalls to be counted over the whole plan period and student/older persons’ housing and the reuse of empty homes to be included when assessing housing need; ensuring that infrastructure is provided to support new development; stressing the re-use of brownfield land; and clarifying the issue of prematurity in relation to draft plans.

Northern Fringe Protection Group

The review of plans and programmes relates to adopted policy. The National Planning Policy Guidance contains details relating to the implementation of the National Planning Policy Framework, the policies of which are referred to in the Scoping Report, and it is therefore not necessary to specifically refer to this. The National Planning Policy Guidance has however been considered when revising the two DPDs.

None

Sections 2.3.9 and 2.3.12 fail to identify from the 2013 Suffolk Growth Strategy (sections 2.26, 4.2, 4.4 & 4.5 refer) the need to ‘transform skills from a growth barrier to a growth stimulus’ and ‘Boost educational attainment, aspiration and employability’.

Northern Fringe Protection Group

The Suffolk Growth Strategy is identified in the Review of Plans, Policies and Programmes in the Scoping Report (2013). It is not necessary to refer to every relevant Plan within this section of the Sustainability Report which essentially summarises the process undertaken in the Scoping Report.

None

Table 2.2: omissions in the summary of sustainability issues and opportunities that need to be corrected, especially in relation to the use of obsolete data. E.g. needs to better represent low education standards in Ipswich; use better health data; address wastewater issues; acknowledge that air quality is worsening in Ipswich and factor in the effect of traffic from the Northern Fringe; acknowledge that Ipswich is not well connected; use better data on pay/benefits; address worsening deprivation; and include empty homes and stock condition data.

Northern Fringe Protection Group

The baseline issues refer to current issues and not those that may arise from policies contained within the plan which are identified through the assessment itself (see chapters 3 and 4). Further assessment of air quality effects arising from development at the Northern Fringe will be addressed. It is not clear what ‘better data’ is available. Table 2.2 identifies that educational attainment is low and identifies issues around Source Protection Zones in relation to water. Deprivation relates to a wide range of topics which have been covered in detail in the Scoping Report and in Table 2.2. Do not agree that Ipswich is not well connected. However the Scoping Report does not identify the water supply issues set out in the recently published Water Resources Management Plan.

Revisions to the baseline identify the possible future revisions to AQMAs.

Anglian Water’s Water Resources Management Plan 2015 (published 2014) has been referred to in the PPP review of the SA Report.

Table 2.3: suggest improvements to objectives and indicators, e.g. ET1 should include an indicator to measure congestion as the main cause of air pollution. Consider consequent changes to Table 2.4.

Northern Fringe Protection Group

It is not clear how congestion would be measured. In relation to air quality congestion is an ‘output’ whereas the indicators proposed would actually measure the ‘outcome’ and are therefore more meaningful.

None

Para. 2.3.27: there will obviously be an increase of traffic during the construction / operation of new residential developments associated with an increase of inhabitants and their future transport requirements, affecting local air quality and climate change. This paragraph needs to be amended or justification why there might be no increase in traffic.

Northern Fringe Protection Group

It is agreed that there is likely to be an increase in traffic and the paragraph should be reworded in this respect.

This has been picked up in the SA.

Para. 2.3.25: question the ‘uncertainties’ arguing they are likely outcomes unless further mitigation steps are implemented. The SA underestimates the impact of objective ER3 which is incompatible with objectives ET1, ET2, ET3, ET4, ET6, ET7 and ET8.

Northern Fringe Protection Group

Paragraph 2.3.26 identifies the reasons for uncertainties however the Sustainability Appraisal process identifies mitigation measures to help to address these, as set out in Appendices E and F of the Sustainability Appraisal Report.

None

Para. 2.3.35: a number of concerns from previous comments on the Scoping Report have not been adequately addressed and need to be revisited as set out below:

Northern Fringe Protection Group

.

See below

See below

Scoping Rpt comment: The NFPG has always supported an employment-led strategy. However, we argued that IBC’s Core Strategy (CS) was not sustainable and therefore unsound as it was based on job targets that had no supporting evidence base and were clearly unrealistic and unachievable. The previous SA failed to recognise these legitimate and material concerns and omitted any form of assessment of the implications of the jobs target being unrealistic. Evidence now shows that the jobs target was indeed unsustainable and that the original SA was incorrect in assessing the CS as sustainable. This clearly shows that a more robust and evidence-based approach for the SA is required that better takes account of the views of the general public which have been shown to be informed and accurate.

Further comment: Why has Hyder ignored the point we are making in its response? The UK recession started in Q2 2008 and was known at the time of Hyder’s SA so it was obvious that delivery was not possible. This does not change the fact that the forecasts were not evidence based and were ludicrously over-optimistic when compared to historic trends. Please explain why Hyder failed to identify these obvious data flaws in its original SA?

Northern Fringe Protection Group

As stated in response to the comment on the Scoping Report, the employment targets are based on the East of England Forecasting Model which is widely used. It is unclear from the response what evidence would lead to the SA assessing the policies differently.

None

Scoping Rpt comment: We are disappointed that IBC has ditched the employment-led strategy despite this being widely supported by officials, councillors, politicians, businesses and the general public in favour of a housing-led approach. This has been done without any assessment or evidence of the relative merits of such an approach compared to a realistic jobs-led strategy and the associated impacts on sustainability. Such an approach is fundamentally flawed.

Further comment: The approach is not policy compliant with the NPPF and guidelines as it does not use DCLG 2011 forecasts and is based on an old EEFM 2012 model run rather than EEFM 2013. The revised strategy fails to take account of a large fall in economic migration and a massive drop in net commuting into Ipswich. It proposes an increase in housing that is not supported by a balanced increase in jobs. It does not contain a specific jobs target and over-estimates the growth prospects of the town centre when compared to the Suffolk Growth Strategy and NALEP strategic plan. How does Hyder intend to factor these points in its SA?

Northern Fringe Protection Group

The objectively assessed housing needs arises from the Ipswich Housing Market Area Strategic Housing Market Assessment (SHMA) (August 2012) and Ipswich Housing Market Area population and household projections: an analysis of demographic change (September 2013).

The SA objectives are based on an analysis of all relevant plans and programmes including those referred to.

None

Scoping Report comment: The SA needs to consider the implications of this key change in IBC’s strategy and in particular consider the implications of new homes being constructed in Ipswich Borough that will result in either higher unemployment levels in the Borough or new residents having to travel outside the Borough to sites of employment. Previously one of the main arguments that the Northern Fringe housing development is sustainable was that residents will walk/cycle or travel by bus to new jobs created in Ipswich town centre, which will no longer be the case in a housing-led strategy. The SA of the Northern Fringe will also need to be revised to take account of this.

Further comments: Why has Hyder chosen to ignore that the net commute into Ipswich is falling from 11.8 (000’s 2001) to 1.1 (2012 based on 2011 employee and 2011 resident employment data)? How will Hyder take this into account in its SA?

Please explain how Hyder considers the Ipswich – Felixstowe train service as a sustainable travel option when there is evidence that it is clearly failing and as the train station is not located near to the major sites of employment? We are pleased to note that Hyder recommends that improved train services from Westerfield station are required.

Currently, the Route 66 service takes 48 minutes from Ipswich train station to Martlesham. For someone travelling from the Northern Fringe it will take between 20-30 minutes to access this service (assuming that the proposed bus route servicing the Northern Fringe arrives at the Cattle Market bus station, which Route 66 serves the station and not Tower Ramparts bus station). It will therefore take around 75-80 minutes to get from the Northern Fringe by public transport to Martlesham Heath which is less than 7 miles away.

Why does Hyder think this will be a sustainable transport route that will be used by residents of the Northern Fringe? This would only work if there was a direct bus route from the Northern Fringe to Adastral Park. We are pleased to note that Hyder recommends that bus services from the Northern Fringe to employment sites are required but Hyder needs to add that these should be direct otherwise few people would use them.

Why has Hyder chosen to ignore that IBC’s forecasts show that there will be more working age people in the Borough competing for less jobs in its answer?

Hyder shows a major lack of understanding of the transport issues facing Ipswich. Please advise how Hyder has attempted to gain first hand experience of these issues and incorporate this knowledge into its SA. Without having this knowledge Hyder’s SA risks being unsound. How does Hyder intend to fill this apparent knowledge gap? We would be pleased to meet with Hyder to share our concerns and first hand experience.

Northern Fringe Protection Group

As stated previously, it does not necessarily follow that a larger workforce would be competing for a smaller number of jobs. Policies would ensure that offices and other town centre uses are focused on the town centre (see policy CS14). The Ipswich Garden Suburb Supplementary Planning Document Interim Guidance (2014) contains specific requirements in relation to public transport and it should therefore not be assumed that only existing patterns of bus provision would be available. It is not the role of the Sustainability Appraisal to identify specific measures to mitigate possible effects but to ensure there are the correct policies in place to secure these measures at the planning application stage which in relation to transport would be through DM17. The SA has been based on the published data available as outlined in the Scoping Report.

None

Scoping Report comment: We support Paragraphs 2.20 and 2.21 of the IBC Executive paper REF NO: E/13/60 Northern Fringe - Draft Supplementary Planning Document Ipswich Garden Suburb and Sustainability Appraisal confirming that the Core Strategy Focused Review (CSFR) “will look at alternatives to the Northern Fringe allocation itself”. The Scoping study must include details of how this will be carried out. This should include a “mapping” of the proposed sites of major employment and new homes in and around Ipswich and analysis of the potential impact and sustainability of likely travel routes. The process should also include an assessment of whether the proposed numbers of proposed new homes and jobs in the area are feasible and sustainable.

Further comments: Why does Hyder not identify that for the Ipswich Housing Market Area it is more sustainable to locate new homes near to the sites of new jobs and that this option is available under the duty to cooperate and should therefore be considered?

How will Hyder assess whether the proposed numbers of proposed new homes and jobs in the area are feasible and sustainable? If Hyder simply assumes IBC’s figures are correct then its SA risks being unsound.

Northern Fringe Protection Group

Consideration has been to given to only allocating 1,500 dwellings at the Garden Suburb however this is judged to be unrealistic, see paragraph 3.3.1 of the SA report for the Proposed Submission Core Strategy.

It should not be assumed that those occupying new homes would only work in ‘new’ jobs, the SA must also give consideration to the location of existing jobs.

The SA objectives are based on the baseline and review of plans and programmes contained in the Scoping Report.

No action needed.

Scoping report comments: The full sustainability implications of the change in the focus of the CS on the wider transport network must also be fully assessed in the SA of the CSFR and in considering alternatives to the Northern Fringe allocation itself. Clearly this can only be completed through detailed traffic assessment and modelling on an integrated basis across Ipswich Borough and in neighbouring authorities that takes full account of relevant employment sites and proposed new housing developments. This needs to assess the impact on air pollution as traffic from the Northern Fringe will pass through AQMAs and areas of pollution concern as residents travel to work.

Further comments: Hyder does not yet fully assess the implications of each policy with regards to travel through ET4 and ET1 as Hyder assumes that new residents will either commute to new jobs in Ipswich town centre rather than the likely sites of new employment or use sustainable transport which is not a viable proposition for residents from most proposed new homes outside the town centre. Hyder also refuses to acknowledge that Air quality is worsening in Ipswich requiring new AQMAs and that residents will want and/or/need to drive through the current and proposed AQMAs. How will Hyder take these points into account to ensure its SA is sound?

Northern Fringe Protection Group

Whilst further reference to possible impacts on AQMAs could be provided, it is not the role of the SA to undertake a full and detailed traffic impact assessment which would be undertaken at planning application stage. The SA does not assume that every resident would travel to new jobs in the town centre, however it considers the location of the Garden Suburb in relation to the town centre where there is a concentration of jobs. It should not be assumed that residents of the new homes would only work in ‘new’ jobs,

Further consideration has been given to the impact on AQMAs in the assessment of CS10.

Scoping Report comments: In particular, the SA of the CSFR needs to consider whether there are alternative brownfield sites outside of the Borough that can accommodate new housing with better access to new sites of employment, such as the Sproughton Sugar Beet site, which would be a more sustainable option than building on the high grade agricultural land of the Northern Fringe with residents commuting through Ipswich to access employment sites. The impact of utilising sites such as Grafton Rd, Cox Lane and Westgate for a larger number of new homes, rather than leaving them vacant, needs to be appraised.

Further comments: Can Hyder explain, its assumption that people living on the Sugar Beet Site would need to travel through Ipswich to access employment sites? It is far more likely the majority would take advantage of the excellent access to the A14 and onwards. Of course there are existing employment sites nearby plus new ones that could be developed on the Sugar Beet site as a shared residential/employment site as well? IBC’s housing growth target of at least 13,550 homes is unachievable within the Borough and relies on windfall sites and neighbouring Local Authorities to make up the shortfall of 4,611 dwellings 11

(Paragraph 8.83 of the Core Strategy). So such sites as the Sugar Beet factory must be considered to help IBC deliver its targets. Hyder’s comment that it cannot as IBC has no control over it implies that the CS is unsound as IBC has no control over delivering its housing target. Can Hyder confirm this or whether it will be assessing such options which are possible under the duty to cooperate? Suffolk Coastal is planning on building new homes to match new jobs created at Adastral yet Hyder in its previous response believes it is acceptable for IBC to also build new homes in the Borough for people to commute to Adastral. Hyder needs to be consistent in its process and appraisal.

Northern Fringe Protection Group

Consideration has been to given to only allocating 1,500 dwellings at the Garden Suburb however this is judged to be unrealistic, see paragraph 3.3.1 of the SA report for the Proposed Submission Core Strategy.

It should not be assumed that those occupying new homes would only work in ‘new’ jobs, the SA must also give consideration to the location of existing jobs.

The plan allocates land at Westgate and Cox Lane for a mix of uses including residential. The site at Grafton Way is now proposed for housing allocation should the extant permission for a mix of uses not be implemented.

It is reasonable to assume that, should the sugar beet factory site be developed for housing, then a proportion of residents would travel into Ipswich for employment. CS7 identifies a need to work with adjoining authorities later in the plan period to meet the residual housing need however this plan cannot itself allocate land within another authority’s area. Mechanisms are in place for this joint work to take place as detailed in the Duty to Cooperate statement.

Consideration has been given to relying on neighbouring authorities and only allocating 1,500 dwellings at the Garden Suburb.

Scoping Report comments: The current CS allows for a phased approach for the development of the Northern Fringe and the previous Suffolk County Council Northern Fringe Sustainability Appraisal and the Core Strategy independent Inspection judged multiple starts as unsustainable. However, the revised CS now allows simultaneous multi-site development across the entire Northern Fringe without any locational restrictions. A detailed examination of the implications of this change must be included in the new SA along with a full assessment of the rationale behind the proposed changes. This should include analysis of the comparative risks of unfinished sites and/or stalled developments being left on the Northern Fringe for whatever reason. This is already a major problem for Ipswich in relation to the waterfront developments, as a result of the unsustainable multi-starts that were allowed to commence and become a major blight on Ipswich.

Further comments: Hyder’s appraisal of revised policy CS10 does not fully consider the implications of multiple starts compared to the original CS10 as we detail in our response to the CS and Northern Fringe SPD consultations. As a minimum the proposals contained in the Northern Fringe SPD must be reflected in the CS and there should be further restrictions to avoid stalled developments and to ensure the required infrastructure delivery relative to the number of homes, especially in relation to the first primary school. Will Hyder reappraise this in light of our comments?

Northern Fringe Protection Group

The SA has considered the allocation as proposed in the level of detail which is proportionate to the purpose of the SA.

A separate SA was undertaken on the SPD and the SPD is identified as mitigation in a number of respects however it would not be appropriate or necessary for CS10 to reiterate the guidance contained in the SPD.

None

Scoping Report comments: Paragraph 3.2.1 needs to reference the proposal for the Core Strategy to no longer be jobs-led but a housing-led strategy. The SA must compare and assess the relative benefits of these alternative strategic approaches and alternatives to the Northern Fringe allocation itself as committed to by IBC in the recently approved Executive paper REF NO: E/13/60.

The paragraph still needs to reference this fundamental change though. Why is Hyder not recommending that IBC uses the DCLG 2011 forecasts to assess housing need as referenced in the NPPF guidance and the most recent EEFM forecasts? These are obviously required for an up to date assessment otherwise the CS risks being unsound.

Further comments: Hyder states that for “employment local and regional strategies aim to play to the area's sectoral strengths.” Why has Hyder not identified that Ipswich town centre has not been identified as a major centre for new jobs in the Suffolk Growth Strategy or the NALEP Strategic Plan and that there is a mismatch between their employment growth sectors and those identified for Ipswich?

Northern Fringe Protection Group

Consideration has been to given to only allocating 1,500 dwellings at the Garden Suburb however this is judged to be unrealistic, see paragraph 3.3.1 of the SA report for the Proposed Submission Core Strategy.

Paragraph 8.137 of the Core Strategy identifies the sectors identified for growth in the NALEP.

Consideration has been given to relying on neighbouring authorities and only allocating 1,500 dwellings at the Garden Suburb.

Scoping Report comments: Paragraphs 3.3.2 and 3.3.11 and Table 3-1 need to specifically reference the CSs of neighbouring authorities and the critical work of the Ipswich Policy Area Board given the duty to cooperate and the proposed approach to build homes in Ipswich Borough for people working outside the Borough. These are more important than the New Anglia Local Enterprise Partnership ‘Towards a Growth Plan’ 2013, which is more of a wish list than an evidence-based document. The quoted growth forecasts are out of date.

Further comments: Will Hyder include in Table 3-1 the Ipswich Policy Area Board’s work, provide updated forecasts and include the recently released NALEP Strategic Plan which has more substance as these are all more relevant. If not, please explain why.

Northern Fringe Protection Group

The review of plans and programmes (see Appendix A of Proposed Submission Core Strategy SA report) includes the NALEP plan and the Suffolk Growth Strategy. Table 3-1 is informed by these. The review of plans and programmes has also considered the adopted plans of adjoining planning authorities. The work of the Ipswich Policy Area Board is committed to through policy CS6 which has been subject to SA but, as a mechanism for joint working, it is not clear how this would be relevant to Table 3-1.

None

Scoping report comments: Table 3-1 should refer to Ipswich Borough-specific data rather than quoting East of England data and should reference the most recent data e.g. the EEFM August 2013 modelling. This projects a lower level of jobs than previously.

2011 2031 Increase

Population 133.7k 163.4k 29.7k (22.21%)

Resident jobs 63.2k 71.4k 8.2k (12.97%)

This means that additional residents will either have to commute outside of Ipswich Borough to find work or will be unemployed; neither of which is sustainable.

Further comments: We are pleased that Hyder will take into account Aug 2013 modelling results but note that it has not yet done so. Hyder should therefore insist that IBC uses most recent data in its analysis otherwise the CS will be unsound. Please confirm this will be the case. If not please explain why Hyder believe it is acceptable to use out of date data.

Northern Fringe Protection Group

The review of plans and programmes has been updated to include reference to the up to date forecasts available at the time of writing. The 2013 forecasts were not significantly different to the 2012 forecasts.

None

Scoping Report comment: Paragraph 3.4.1.3 Ipswich Central’s vision for Ipswich needs to be considered http://ipswichcentral.com/thebigdebate/ along with the work of the Ipswich Policy Area Board especially in relation to employment and the 2012 Air Quality Updating and Screening Assessment for Ipswich Borough Council (January 2013), which concludes that “St Matthews Street and Woodbridge Road are both areas where NO2 results were high. These areas have therefore undergone a detailed assessment and as a result AQMA’s will be declared. “.

Please confirm that Ipswich Central’s vision for Ipswich will be considered by Hyder in the SA. If not, please explain why?

Further comments: Please confirm that the impact of the revised CS on the additional AQMAs will be considered in Hyder’s SA. If not, please explain why? The approximate sites of the AQMAs are known so there is no reason why they should not be considered.

Northern Fringe Protection Group

The vision for Ipswich Central can be included in the review of plans and programmed.

The potential impact on AQMAs has been considered in relation to policy CS10.

This has been included within the review of plans and programmes,

Table 3-2 needs to reference the proposed new AQMAs (as does Appendix B.7) as referenced above and utilise more recent data where available. There are also opportunities to improve cross-town transport infrastructure and access to the A14/A12. This will become a fundamental requirement if the CS is changed to housing-led as residents will need to be able to easily commute to employment sites outside the Borough.

The fact that new AQMAs are proposed still needs to be referenced here. Please explain why Hyder continues to ignore this worsening environmental issue in its report.

Please confirm that Hyder’s SA will consider the additional cross-town transport infrastructure and improved access to the A14/A12 that will be required to mitigate the impact of the change in strategy to a housing led one? If not, please explain why?

Northern Fringe Protection Group

The baseline (Appendix B of the Proposed Submission Core Strategy SA report) has been updated to reflect the current situation surrounding AQMAs.

Mitigation measures have been identified in relation to transport where necessary throughout the assessment.

None

Scoping Report comments: Paragraph 4.1 As the CSFR proposes to a housing-led strategy with residents commuting to jobs outside of Ipswich Borough, the SA clearly needs to undertake a full and detailed assessment of the associated travel implications outside of Ipswich Borough.

Further comments: As mentioned earlier, the EEFM 2013 shows that the net commute into Ipswich is falling from 11.8 (000’s 2001) to 1.1 (2012 based on 2011 employee and 2011 resident employment data)? With the proposed shift to a housing-led strategy and lack of new jobs being created in the town centre, residents will have to increasingly commute to jobs outside Ipswich Borough. This is obviously a major sustainability issue that must be considered fully in the SA. How will Hyder take this into account in its SA?

Northern Fringe Protection Group

The SA has considered the relationship between new housing in terms of both the location of new jobs and the location of existing ones, through SA objective ET4.

None

Need to make clear that the proposed CSFR is no longer a jobs-led strategy but a housing-led strategy. To fail to mention this fundamental change is misleading and lacks transparency. Likewise the major proposed changes to CS10 need to be outlined here i.e. the intention to allow simultaneous multiple starts across all three areas of the NF without restricting the number of construction sites at any one time etc and prior to the agreement of a Masterplan also needs to be specifically mentioned.

As these are major changes they should still be referenced here. If not, why not?

Northern Fringe Protection Group

The geographical scope of the SA which has not changed. The SA assesses the policies as they are presented in the Proposed Submission Core Strategy. Section 4.3 of the SA report of the Proposed Submission Core Strategy identifies the main changes since the earlier draft.

None

Scoping Report comments: Paragraph 4.2.2.1 As stated above, the SA of the CSFR needs to assess the alternative of an evidenced-based jobs-led strategy. It also needs to assess the alternative of a phased and controlled development of the Northern Fringe that does not allow multi-site starts or places restrictions on when the three areas of the NF can be developed and/or on the number of sites that can be developed in any one area at the same time.

Hyder’s SA does not assess the alternative of an evidence based jobs-led strategy. It does not take into account;

o most recent EEFM forecasts,

o major net-commuting changes,

o the Ipswich SHMA uses obsolete DCLG and not more recent 2011 data,

o recent local economic migration figures,

o that Ipswich town centre is not identified as a major growth centre in either the Suffolk Growth Strategy or NALEP Strategic Plan,

o an over-reliance of IBC on major retail development in the town centre.

Further comments: Please explain how Hyder intends to incorporate these key issues into its analysis.

Northern Fringe Protection Group

The National Planning Policy Framework requires planning authorities to plan to meet their objectively assessed housing need and the consideration of alternatives in relation to this have been set out in section 3.3 of the SA of the Proposed Submission Core Strategy. The retail proposed for the town centre is based upon the DTZ 2013 Town Centre Opportunity Areas report. The Suffolk Growth Strategy and the NALEP Plan are included within the baseline which has informed the sustainability objectives. The 2013 EEFM data was not available to inform previous drafts and it is considered that the difference between this and the 2012 data is not significant.

Para. 2.4.4: removal of a Previously Developed Land target from policy CS9 is a major change and therefore needs to be part of the SA.

Northern Fringe Protection Group

Appendix C of the Strategic Environmental Assessment and Sustainability Appraisal of the Focused Review of the Core Strategy and Policies Development Plan Document (Hyder, December 2013) outlines the implications of the change to the Policy CS9.

None

Para. 3.1.1: the original SA was flawed because it did not look at alternatives to the policies other than ‘do nothing’. The SA of the Core Strategy review must assess alternatives.

Northern Fringe Protection Group

Whilst alternatives in Ipswich are limited, it is agreed that whilst higher density development may not be a viable alternative at this point in time it may be in the future and this will be considered as an alternative.

The SA has considered higher densities in Ipswich Borough as a strategic alternative to addressing housing need through working with neighbouring authorities.

Table 3.1: should assess changes to policy CS9. Policy CS7 – the most recent data should be used, and reliance on windfalls and neighbouring authorities noted. Policy CS10 – the negative impacts on brownfield development should be considered and wording on phasing looked at. Policy CS13 – should require that the latest East of England Forecasting Model (EEFM) 2013 data are used, and assess growth areas relative to the EEFM / New Anglia Local Enterprise Partnership Strategic Economic Plan / Suffolk Growth Strategy. Policy CS14 should take better account of Ipswich Central’s views on the retail sector. Policy CS17 should check for and eliminate unintended consequences.

Northern Fringe Protection Group

Appendix C of the Strategic Environmental Assessment and Sustainability Appraisal of the Focused Review of the Core Strategy and Policies Development Plan Document (Hyder, December 2013) outlines the implications of the change to the Policy CS9.

It is agreed that the Sustainability Appraisal should consider the potential effects of the longer term policy of working with neighbouring authorities.

The Ipswich Garden Suburb is proposed to come forward alongside the land allocated for brownfield development within Ipswich and therefore it is not appropriate for the SA to assess any implications of brownfield land not coming forward.

Policy CS13 is based upon the most up to date EEFM data available.

Without clarity over specifically which of Ipswich Central’s views are considered to be not represented, it is considered that the policy is consistent with the aims of Ipswich Central and the supporting text includes reference to working with Ipswich Central.

It is not clear what unintended consequences are being referred to however the policy contains flexibility relating to the viability of individual developments.

The Sustainability Appraisal has been revisited in order to consider the effects of working with neighbouring authorities to meet housing need later in the plan period and to consider the strategic alternative of higher density development within Ipswich.

Table 4.1: the wider implications of the change to policy CS9 [brownfield target] needs to be considered alongside the options for keeping a target at a reduced level.

Northern Fringe Protection Group

Appendix C of the Strategic Environmental Assessment and Sustainability Appraisal of the Focused Review of the Core Strategy and Policies Development Plan Document (Hyder, December 2013) outlines the implications of the change to the Policy CS9.

None

Para. 4.3.4: the SA needs to recognise that the Core Strategy needs to be better balanced to improve the lives of existing residents through redeveloping poor housing stock, tackling deprivation, reducing crime, improving health, getting people off benefits and back to work. The SA focuses too much on the advantages of new homes to the new residents and the averaging effect of these developments across Ipswich rather than on existing residents in existing wards who will remain disadvantaged and in need.

Northern Fringe Protection Group

These are planning documents and therefore have limited influence over existing dwelling stock. Policies which promote new employment opportunities relate as much to existing residents as to new residents.

None

Para. 4.3.5: the policies do not consider the likely location of new homes to new employment sites, or that new residents in Ipswich Borough will have to commute outside of the Borough to new sites of employment. The policies do not consider the implication of having insufficient jobs to match the number of new residents looking for employment.

Northern Fringe Protection Group

Policy CS13 plans to provide sufficient employment development to provide for the jobs forecast. It should not be assumed that those living in new homes will only be employed in ‘new’ jobs.

None

Para. 4.3.7: pleased the SA recognises the travel implications in relation to housing development of the Northern Fringe. However, this needs to be better reflected throughout its assessments.

Northern Fringe Protection Group

Further consideration is being given to assessing traffic (air quality) implications of the Garden Suburb development. However, transport impacts and mitigation measures would need to be considered in detail as part of the planning applications, as identified in the Ipswich Garden Suburb Supplementary Planning Document Interim Guidance (2014).

Further consideration to air quality / transport has been given through the Sustainability Appraisal process.

Para. 4.3.10: following recommendations are required: most recent population and employment data should be used and forecasts should be made across district boundaries; a firm jobs growth target will help focus delivery; a better balance between new jobs and homes is needed with homes built near jobs; less reliance on retail growth and better alignment with New Anglia Local Enterprise Partnership growth sectors; a Previously Developed Land target should be reintroduced; policy CS10 and Table 8B should be revised to remove risk of unintended consequences; water supply and sewerage should be addressed; and more should be done to improve the lives of existing residents.

Northern Fringe Protection Group

Policy CS13 plans to provide sufficient employment development to provide for the jobs forecast. It should not be assumed that those living in new homes will only be employed in ‘new’ jobs.

Retail growth is based upon the recommendations of the 2013 Appraisal of Ipswich Town Centre Opportunity Areas study by DTZ.

Due to the need to bring forward the Garden Suburb in tandem with brownfield sites it is not appropriate to set a target for brownfield development.

Developers and Anglian Water are in discussion on what capacity improvements will be required in relation to the Garden Suburb development.

There are a range of policies in the Plan which are intended to improve the lives of existing residents however in terms of provision of housing the plan has little influence over improving current stock. It should not be assumed that new housing would only be occupied by new residents.

None

Table 4.2: needs to recognise the plan does little to improve educational standards in existing schools; little to tackle crime in existing wards, while promoting homes without jobs; little to improve health especially for those in poor housing stock; and nothing to redevelop/improve sub-standard housing. It uses obsolete jobs data and forecasts far exceed historic provision. Impacts on climate change will be negative and the potential sewage issues associated with growth have not been addressed. These omissions need to be rectified as a key objective.

Northern Fringe Protection Group

Policy CS13 plans to provide sufficient employment development to provide for the jobs forecast. As a planning document, the plan has limited influence over improving existing stock and directly tackling poor health or improving educational standards.

Policy CS17 identifies utilities as infrastructure that would need to be funded by new development.

None

Appendix E and Appendix F: as the jobs and homes data used in the Core Strategy is obsolete, have deferred commenting on the specific Impact Assessments until more recent data is utilised.

Northern Fringe Protection Group

Noted. The data used is the most up to date available at the time the Sustainability Appraisal was undertaken.

None

Inconsistencies in the Core Strategy car parking policy and ambiguity in relation to the Bury Road Park and Ride which the Site Allocations development plan document assumes will be reopened and enlarged while the Core Strategy deletes reference to a new park and ride (page 74). The proposals for IP-One expand existing car park capacity but it is rarely insufficient to meet demand. Also inconsistent with the aim for more people to walk and cycle and the reopening / extension of Bury Road Park and Ride. The SA needs to consider these issues accordingly.

Northern Fringe Protection Group

The park and ride reference deleted was in relation to Nacton Road. It should be noted that the proposed extension to the Bury Road park and ride has been deleted due to uncertainty surrounding its future.

None

Evidence base is contested in relation to population projections and employment modelling. Previous rates of forecast jobs growth have not been delivered. Result is high youth unemployment and a low waged and low skilled economy. Impacts of lack of employment need to be assessed against statistics for problematic levels of crime and anti-social behaviour. None of this is explored in the SA. Support the Northern Fringe Protection Group analysis of the jobs issue.

Save Our Country Spaces

As the plan is proposing to support jobs growth, it is unclear how the SA would conclude that this will increase unemployment and crime. Current issues around these are identified in the sustainability issues summary (Table 2.2) and in the baseline in the Scoping Report.

None

Assumptions, projections and estimates behind the growth agenda pursued since 2001 have not stood the test of time. New jobs have not materialised and Ipswich has lost manufacturing jobs. Result is a predominantly low waged and low skilled economy with a high level of youth need. Ipswich housing is relatively cheap and Ipswich has high urban densities compared to Suffolk. Thus Ipswich features adversely in terms of deprivation in the Institute for Economics and Peace study April 2013. The SA should examine the impacts of lack of employment together with crime and anti-social behaviour statistics.

Save Our Country Spaces

As the plan is proposing to support jobs growth, it is unclear how the SA would conclude that this will increase unemployment and crime. Current issues around these are identified in the sustainability issues summary (Table 2.2) and in the baseline in the Scoping Report.

None

Policy gaps in the Core Strategy review including transport. Ipswich Borough Council has not allowed the known impacts of new development on the transport system to be enshrined in the Core Strategy and to be properly recognised and identified with adverse impacts on air quality, congestion and road safety covered by Section 106 agreements. SA needs to revisit the saved policies from the 1997 Ipswich plan and take account of the policy direction contained in it.

Save Our Country Spaces

Further consideration is being given to assessing traffic (air quality) implications of the Garden Suburb development. However, transport impacts and mitigation measures would need to be considered in detail as part of the planning applications, as identified in the Ipswich Garden Suburb Supplementary Planning Document Interim Guidance (2014).

Further consideration to air quality / transport has been given through the Sustainability Appraisal process.

No consistency with previous SA work [on CS10], in particular: regarding high levels of house building; mitigation measures required in the event of slow delivery at the Northern Fringe, not allowing multiple starts which could affect community networking; possible adverse impacts on Fynn Valley; the need to adopt the supplementary planning document before permission is granted for development on SA grounds; bringing forward the start date may undermine previously developed land delivery; the need for a country park as soon as development begins; and viability considerations impacting on open space provision.

Save Our Country Spaces

In order to meet housing need, the Garden Suburb development needs to come forward alongside the redevelopment of brownfield land. It is anticipated in the Supplementary Planning Document Interim Guidance (2014) that around 200 would be built per year from 2018 with housing also coming forward at other locations. The Supplementary Planning Document Interim Guidance (2014) requires initial work at the country park to take place in the early stages of development of the Henley Gate neighbourhood.

None

Query the scoring in the SA. SA should also be an iterative process but to date it has failed to be. Not reassured by the SA and its unconvincing rhetoric contained within the statements and conclusions. The Institute for Economics and Peace 2013 is not referenced or considered. The SA refers to ‘revised policies also found to detract from some SA objectives with potential to have negative effects if no mitigation measures are out in place’. What contingencies are proposed if effective mitigation cannot be achieved, particularly around traffic, pollution and flood risk?

Save Our Country Spaces

The SA has influenced the development of the Core Strategy and Policies DPD through the incorporation of mitigation measures where possible / appropriate.

It is not possible for the SA at this level to identify precise effects which can only be identified at the planning application stage.

It is not clear in what way the Institute for Economics and Peace should be referred to.

None

Concerned about the impacts on the existing population. If the Ipswich Garden Suburb is not successfully delivered or competently managed, there will be profound adverse consequences for future generations. A key requirement of sustainable development is that future generations will not be compromised (Brundtland).

Save Our Country Spaces

The Ipswich Garden Suburb Supplementary Planning Document Interim Guidance (2014) contains detailed measures in relation to securing appropriate infrastructure at the planning application stage.

None

Lack of assessment and possible necessary mitigation for impacts on Suffolk Coastal District Council adjacent villages. There is a duty under the adopted Core Strategy and SA work to assess other local authority growth plans and also mitigate pressures on local Ramsar sites and County Wildlife Sites, e.g. Fynn Valley, which will be adversely impacted and put under intolerable pressure by the Northern Fringe development and development in other authority areas.

Save Our Country Spaces

The Habitats Regulations Assessment process has considered the ‘in-combination’ effects of development in Ipswich and in Suffolk Coastal on the Stour and Orwell Estuaries SPA. The provision of the country park at the Garden Suburb acts as mitigation.

None

Ipswich has failed to hold congestion at 1999 levels or stabilise air pollution. It has a serious and growing air pollution problem which will be further impacted by these plans [for development at the Northern Fringe] as the development is adjacent and will feed through Air Quality Management Area risk zones to travel to the town centre or schools. The SA assessment of this is flawed.

Save Our Country Spaces

The SA identifies that there will potentially be negative effects on air quality from the Garden Suburb development.

None

Unsustainable loss of best and most versatile agricultural land is objected to. It will compromise future generations and the rural economy by the loss of agricultural jobs.

Save Our Country Spaces

There is insufficient brownfield land in Ipswich to meet housing needs. The SA has noted the potential negative effects on agricultural land.

None

The railway causes significant noise nuisance problems from freight movements at night. Increased use of the Felixstowe line needs assessing in relation to the Red House site. The SA makes no mention of this and guidance must be sought from expert stakeholders e.g. Suffolk County Council Noise and Air Quality Manager.

Save Our Country Spaces

It is agreed that the SA has not identified potential noise issues in relation to the Garden Suburb. However it should be noted that the Supplementary Planning Document Interim Guidance (2014) identifies noise as an issue to be addressed through the Environmental Impact Assessment of any planning application.

The assessment of Policy CS10 identifies noise from the Garden Suburb as a potential issue against SA objective HW2.

Comments on the Scoping Letter Issues in September 2014

Respondent

Summary of Response

IBC response

Suggested Action

Babergh District Council and Mid Suffolk District Council

No comments

Noted

No action needed

Natural England

Satisfied with the scope of the SAs as proposed.

Noted

No action needed

Supports the proposal to update the evidence base including a refresh of baseline information, key issues within Ipswich and the plans review.

Noted

No action needed

The need to address potential recreation pressures on the Stour and Orwell Estuaries SPA and Ramsar site will need to be addressed through the SA.

This is being addressed primarily through the Habitats Regulations Assessment process but the conclusions will need to be reflected in the SA.

Once updated, the HRA report results will need to be reflected in SA.

English Heritage

Would like to review the Core Strategy and the Site Allocations DPDs before the next consultation, in relation to comments made previously about the NPPF requirements for a positive strategy in relation to heritage not being met.

A copy of the latest versions of the Core Strategy and Policies DPD and the Site Allocations DPD (as at 10.10.14) have been sent to English Heritage.

No action needed

Refers to comments made in relation to the previous consultation dated 28th November 2013 and on the interim SA reports.

Comments on the previous SA consultations have been taken on board, as detailed in Appendix D of the Interim SA report published in January 2014.

No action needed.

Consideration should be given to alternative spatial options (or sites) in relation to the SA of the Site Allocations document.

Due to the constrained nature of Ipswich Borough there are limited opportunities for meeting the objectively assessed housing need and therefore sites that are appropriate in planning terms and that could realistically be delivered during the plan period have been allocated.

The revised SA of the Core Strategy will include an assessment of alternative spatial options along with reasoning as to why the options were discounted or not considered reasonable. In addition, the revised SA of the Sites DPD will include alternative site allocations that were discounted for various reasons.

Awareness and understanding of the historic environment of archaeological sites and issues was limited in both the site allocations document and sustainability appraisal report issued for consultation in early 2014 and needs addressing as a priority. This includes identifying locations of Scheduled Monuments within the Site Allocations document and understanding the potential of non-scheduled sites, particularly where site allocations are proposed.

The SA baseline identifies the heritage assets within Ipswich along with noting the concentration of assets within central Ipswich.

Details of the relevant heritage assets will be referred to on the sites sheets which form part of the Site Allocations document. The SA will also have regard to non-scheduled sites.

Welcome the amended wording to SA objective ET9. In the first sub-objective the term ‘historic buildings and sites’ could be replaced with ‘heritage assets’.

This change would be appropriate as it would align the sub-objective with the NPPF.

The sub-objective will be amended.

Anglian Water

Satisfied that the report covers essential matters including the need to protect the water environment and the need to adapt to threats posed by climate change.

Noted

No action needed

Northern Fringe Protection Group

The SA could better assess the number and location of new jobs to be created in the Borough relative to new housing, and the implications for the transport network and air pollution. The SA currently assumes a vast number of jobs being created in the town centre but without an evidence base to support this assumption. Air pollution should be considered in relation to EU legal requirements.

The purpose of the SA is to assess the contents of the Core Strategy and Sites DPDs. The SA of the Core Strategy has reiterated the number of jobs that will be created in the borough as stated in the Core Strategy and based on the evidence for that.

Job forecasts in the Core Strategy have come from the East of England Forecasting Model.

The SA will consider the potential cumulative effects of new housing and employment generation on vehicle movements, air quality and carbon emissions across Ipswich.

Environment Agency

No comments

Noted

No action needed

Save Our Country Spaces

The previous SA did not recognise the job targets were not realistic and were unachievable. The SA should be more evidence based and take account of the views of the public.

The role of the SA is not to challenge evidence produced as part of the production of the Core Strategy but to assess policies based upon the range evidence and information available (including evidence and data produced outwith the plan production process), including the views of the public gathered through consultation.

No action needed

Disappointed that an employment led strategy has been abandoned without assessment of the effects. The SA should therefore consider the effects of housing resulting in higher levels of unemployment / commuting.

The SA Framework contains objectives that seek to improve the local economy, create new jobs, promote sustainable transport and reduce private car use.

Policies CS7 and CS10 within the Core Strategy will be assessed against these objectives.

Higher levels of housing and a larger workforce could have implications on salary levels and therefore poverty levels and this needs to be considered by the SA.

SA objective ER2 enables consideration to given to the effect of policies on rewarding and satisfying employment opportunities and objective ER1 considers poverty.

No action needed

The impacts on the wider transport network of the change in focus of the Core Strategy should be assessed. Detailed traffic assessment and modelling needs to be undertaken across Ipswich Borough and neighbouring authority areas, taking account of employment sites and housing sites. This is required under the Duty to Cooperate. This needs to consider impacts on air pollution including AQMAs – traffic from the Northern Fringe will pass through AQMAs.

Further consideration will be given to air quality effects arising from the Garden Suburb development. However, detailed traffic assessments would be undertaken at the planning application stage.

The SA of the Core Strategy and Sites DPDs will consider the potential cumulative effect of increasing housing and jobs on traffic movements and air quality.

The SA should assess and compare the sustainability benefits of a realistic jobs-led Core Strategy and a housing-led Core Strategy, including assessments of a co-operative approach between Ipswich Borough and neighbouring authorities.

The Draft Core Strategy and Policies Focused Review – Interim SA Report (December 2013) assessed the ‘new’ policies against the adopted 2011 policies in this respect and provided commentary on this.

None

The SA lacks data in relation to monitoring air quality impacts from traffic, particulate impacts and impacts on health from air pollution, including cumulative and compound impacts from multiple sources of air pollution, including impacts from Europe.

Further consideration will be given to air quality effects arising from the Garden Suburb development. Unclear how impacts from Europe could affect Ipswich. It should be noted that mitigation will be / is provided within the Garden Suburb SPD and the proposed Low Emissions SPD and Cycling SPD.

The SA of the Core Strategy and Sites DPDs will consider the potential cumulative effect of increasing housing and jobs on traffic movements and air quality.

The SA needs to consider the impact of the levels of housing being proposed on jobs, in terms of higher unemployment in the Borough or residents commuting to elsewhere. The SA needs to consider the effect of a larger number of residents competing for a smaller amount of jobs and take account of average salary levels in Ipswich. The SA of the Northern Fringe will need to be revised to take account of this.

Job forecasts are provided through the East of England Forecasting Model. The provision of homes to meet labour supply requirements is covered by the final sub-objective under SA objective ER2. However, whilst there is a link between number of jobs and provision of housing there is no simple ‘ratio’ that can be applied due to the multiple variables involved. The Core Strategy plans to meet both the land requirements of the jobs forecast and, as far as possible, the housing needs. The baseline of the SA identifies that Ipswich has lower than average salary levels. The 2012 Strategic Housing Market Assessment concluded that household projections would be broadly similar under either the DCLG household projections (population based) or the East of England Forecasting (labour market projections).

The updated Employment Topic Paper will provide greater explanation of the relationship between housing and jobs provision.

Reference should be made to the implications of the recent Defra consultation on local air quality monitoring.

As a final document has not been published there is no certainty over future changes to local air quality management. The consultation set out a range of options however the purpose of any changes is to focus more action on meeting EU targets and less on the reporting and monitoring processes themselves. This overall intention could be referred to in the assessment of plans and programmes.

The ‘Local Air Quality Management

Consultation on options to improve air quality management in England’ consultation (DEFRA, 2013) will be added to the review of relevant plans, programmes and environmental objectives in the SA Report appendices along with an explanation of its significance as per our response in the column to the left.

The SA must consider the implications of the Core Strategy allowing the Northern Fringe developments to come forward simultaneously rather than in a phased manner. There may be implications if one or more developers or landowners have financial issues, this may have implications for infrastructure delivery. The use of Grampian conditions or a safety net fund could help to avoid such issues.

The Draft Core strategy and Policies Focused Review – Interim SA Report (December 2013) considered effects of 3,500 dwellings being provided at the Garden Suburb by 2031.

The SA will consider the implications of all housing at the Garden Suburb.

Comments submitted in relation to previous consultations were submitted as appendices.

Noted. Actions have been made in relation to these comments where relevant/appropriate through previous iterations of the SA, as detailed in appendices to the SA reports.

No action needed.

Save Our Country Spaces

(received late)

The Housing Charter for Suffolk should be considered as part of the SA process.

At present the Housing Charter is in draft format, if finalised prior to the submission of the SA it will be added to the plans, programmes and environmental objectives appendix of the SA Reports. However, it should be noted that its inclusion would not affect any conclusions in the SA.

No action needed.

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