Strategic Environmental Assessment and Sustainability Appraisal - Site Allocations and Policies (incorporating IP-One Area Action Plan) DPD

Ended on the 5 March 2015

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2 SUSTAINABILITY APPRAISAL

2.1 Legal Requirements

2.1.1 It is a legal requirement that the Site Allocations DPD is subject to SA, under the Planning and Compulsory Purchase Act 2004. This Act stipulates that the SA must comply with the requirements of the SEA Directive which was transposed directly into UK law through the SEA Regulations²

2.1.2 The aim of the SEA is to ‘provide for a high level of protection of the environment and to contribute to the integration of environmental considerations into the preparation and adoption of plans and programmes with a view to promoting sustainable development’(Article 1 of the SEA Directive).

2.1.3 A combined SA and SEA has been undertaken, as the Site Allocations DPD has the potential to have a range of significant sustainability effects (both positive and negative). The SA has been undertaken in accordance with guidance from the Planning Advisory Service (www.pas.gov.uk/pas/core/page.do?pageId=152450). In addition, published Government guidance on SEA³ (hereafter referred to as the Practical Guide) has also been followed.

2.2 Stages in the SA Process

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

2.2.2 Table 2-1 presents a summary of the key stages of the SA process, together with the SEA Directive requirements for each stage. Reference is given to where the requirements have been addressed within this SA Report.

Table 2-1 Stages in the SA Process and SEA Directive Requirements

SA Stage	Key SEA Directive Requirements	Relevant Section of the SA Report	Application to the Site Allocations DPD
Stage A: Setting the context and objectives, establishing the baseline and deciding on the scope
A1: Identifying other relevant policies, plans and programmes and sustainability objectives	The Environment Report should provide information on: “the relationship (of the plan or programme) with other relevant plans and programmes” (Annex 1(a)) “the environmental protection objectives, established at international (European) Community or Member State level, which are relevant to the plan or programme and the way those objectives and any environmental considerations have been taken into account during its preparation”(Annex 1(e))	Chapter 2 and Appendix A.	Stage A corresponds to the scoping stage of the SA and the findings of this stage are presented in the Scoping Report that was consulted upon in October / November 2013. Following the changes to the structure of the plan in Summer/Autumn 2014 a further scoping letter was produced which was consulted upon in September and October 2014. During this stage the scope of the SA for the Site Allocations was defined.
A2: Collecting baseline information	The Environment Report should provide information on: “relevant aspects of the current state of the environment and the likely evolution thereof without its implementation of the plan or programme’ and, ‘the environmental characteristics of the areas likely to be significantly affected” (Annex 1(b),(c)) “ any existing environmental problems which are relevant to the plan or programme including, in particular, those relating to any areas of a particular environmental importance, such as areas designated pursuant to Directives 79/409/EEC and 92/43/EEC”(Annex 1 c))	Chapter 2 and Appendix B
A3: Identifying sustainability issues and problems		Chapter 2
A4: Developing the SA Framework	N/A	Chapter 2
A5: Consulting on the scope of the SA	The authorities referred to in Article 6(3) shall be consulted when deciding on the scope and level of detail of the information which must be included in the environmental report.(Article 5.4)	The scope of the appraisal is presented in Chapter 2. A Scoping Report was produced and consulted upon.
Stage B: Developing and Refining Options and Assessing Effects
B1: Testing the Site Allocations DPD’s objectives against the SA Framework	The Environment Report should consider “reasonable alternatives taking into account the objectives and the geographical scope of the plan or programme” and give “an outline of the reasons for selecting the alternatives dealt with” (Article 5.1 and Annex I(h)) In the Environmental Report, “the likely significant effects on the environment of implementing the plan or programme ... and reasonable alternatives ... are [to be] identified, described and evaluated” (Article 5.1)	Chapters 3 and 4 and Appendix D, E, F, G.	Stage B of the SEA process is linked to the overall production of the Site Allocations DPD which includes the development of the site allocations and preferred options. This SA Report presents the findings of the assessment of policies and site allocations.
B2: Developing the Site Allocations DPD Options
B3: Predicting the effects of the Site Allocations DPD
B4: Evaluating the effects of the Site Allocations DPD
B5: Considering ways of mitigating adverse effects and maximising beneficial effects	Annex I (g) states that it should also include “measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the environment of implementing the plan or programme...”
B6: Proposing measures to monitor the significant effects of implementing the Site Allocations DPD	The Environmental Report should provide information on “a description of the measures envisaged concerning monitoring” (Annex I (i))
Stage C: Preparing the SA Report
C1: Preparing the SA Report	Article 5.1 contains the requirement for an environmental report to be produced where an assessment is required. The environmental report “ shall include the information that may reasonably be required taking into account current knowledge and methods of assessment, the contents and level of detail in the plan or programme, its stage in the decision-making process and the extent to which certain matters are more appropriately assessed at different levels in that process in order to avoid duplication..” (Article 5.2). Details of the information to be given in the Environmental Report are provided in Annex 1.	This Interim SA will inform the preparation of the draft SA Report. Following the informal consultation, a draft SA Report will be prepared.	A SA Report will be produced in line with the requirements of the SEA Directive for producing an Environmental Report. A Non-Technical Summary will also be included with the SA Report.
Stage D: Consultation on the Site Allocations DPD and the SA Report
D1: Public participation on the proposed submission documents	Article 6 contains the requirements for the draft plan or programme and the environmental report to be made available to statutory authorities and the public. They should be given an ‘ early and effective opportunity within time frames to express their opinions’ (Article 6.2).		The SA Report accompanying the Proposed Submission Site Allocations DPD will be consulted upon in accordance with Regulation 19 and 20 of the Town and Country Planning (Local Planning) (England) (Amendment) Regulations 2012.
D2: Appraising significant changes resulting from representations	N/A	N/A	Following the receipt of representations, the SA Report may need to be updated to reflect comments received as part of the Examination process. It will be essential for the SA Report and the Site Allocations DPD to remain consistent.
D3: Making decisions and providing information	N/A	N/A
Stage E: Monitoring the significant effects of implementing the Site Allocations DPD
E1: Finalising aims and methods for monitoring	“Member States shall monitor the significant environmental effects of the implementation of plans and programmes... in order, inter alia, to identify at an early stage unforeseen adverse effects, and to be able to undertake appropriate remedial action” (Article 10.1)		Monitoring undertaken for the SA process should feed into the Authority Monitoring Report (AMR).
E2: Responding to adverse effects

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

2.3 Stage A: Setting the Context, Establishing the Baseline and Deciding on the Scope

Review of Plans, Policies and Environmental Protection Objectives

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

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

The SEA Directive requires that the SEA covers:

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

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

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

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

2.3.3 The review included documents prepared at international, national, regional and local scale. A brief summary of the documents reviewed and the main findings are summarised below with further details presented in Appendix A.

International Plans and Programmes

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

National Plans and Programmes

2.3.5 A review was undertaken of relevant White Papers, plans and strategies. One of the most important documents reviewed was the UK Sustainable Development Strategy⁴ which outlines the over-arching Government objective to raise the quality of life in our communities.

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

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

2.3.8 The NPPF guidance is structured around the following sections:

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

Regional and Sub-Regional Level Plans

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

2.3.10 The Localism Act was granted Royal Assent on 15th November 2011. This Act seeks to rescind some regional planning documents such as the East of England Plan (Regional Spatial Strategy 2008) which was revoked in 2013.

Local Policy

2.3.11 Plans produced at the local level specifically address issues relating to the economy; health; safety; tourism; sustainable communities; housing; employment; and physical activity. The Site Allocations DPD and the SA should draw from these documents and transpose their aims in their policies and proposals. These local policy plans have been instrumental in the development of the SA Framework (refer to Section 2.4). These plans should in theory have included the main influences of international, national, regional and county level plans through the ‘trickle-down effect’. They should also provide more of a local focus for the Ipswich area. It is through identifying these themes and incorporating them into the Site Allocations DPD that synergies can be achieved with other relevant documents.

Key Results from the Review

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

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

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

The Sustainability Baseline and Key Sustainability Issues

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

Box 2: SEA Directive Requirements for Baseline Data Collation

The SEA Directive requires that the SEA covers:

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

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

Methodology

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

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

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

Review of relevant local, sub- regional, regional, national and international plans, policies and environmental protection objectives;
Data gathering using a series of baseline indicators developed from the SEA Directive topics (biodiversity, population, human health, flora, fauna, soil, water, air, climatic factors, material assets, cultural heritage including architectural and archaeological heritage and landscape). This included advice in A Practical Guide to the Strategic Environmental Assessment Directive from the ODPM, previous consultation recommendations from other SAs and the range of data available for the Borough. Data has also been collated for additional socio-economic topic areas including deprivation, housing and employment to ensure that a broad range of environmental, social and economic issues are considered.
Consideration of the scope and contents of the Site Allocations DPD.

2.3.17 A detailed description of the baseline characteristics of the Ipswich area is provided in Appendix B.

Key Sustainability Issues and Opportunities

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

Table 2-2 Summary of Key Sustainability Issues and Opportunities in Ipswich

SA Topic	Key Sustainability Issues	Key Sustainability Opportunities
Population	Ipswich has the highest population of all the districts within Suffolk. The level of projected population growth within Ipswich is relatively high and so a large number of new homes is considered necessary within Ipswich in order to meet the needs of all members of the population. There are potential challenges that could arise in the future relating to the type and tenure of housing provision on offer in the Borough. These issues include provision of homes for the elderly that meet needs such as accessibility, the provision of affordable homes, and the provision of smaller homes with one to two and two to three bedrooms. There is a high percentage of people under the age of 34 in Ipswich, which may have implications for provision of educational facilities, recreational facilities etc. Asian/Asian British are the main ethnic minority representing 6.3% of the population and therefore there needs to be appropriate services provision for all members of the population in terms of education, housing etc.	There are opportunities to improve the supply of housing, education, health and other community facilities within the Borough through allocating sufficient land to meet objectively assessed housing need in accordance with the Strategic Housing Marketing Assessment 2012 and allocating land for community facilities. Planning for a rise in the number of primary school age children is necessary, where appropriate, based on the level of forecast population growth and demand. Additionally, supporting the completion of regeneration projects at the Waterfront would provide opportunities to address some issues relating to the provision of housing and community facilities.
Education and Qualifications	Educational attainment across Ipswich is below the national average. However, the percentage of population holding recognised qualifications is average across Ipswich with numbers of those with no qualifications and achieving National Vocational Qualification (NVQ) Level 4 similar to regional and national averages. Gipping, Priory Heath, Whitehouse, Castle Hill, Stoke Park, Rushmere, Sprites and Gainsborough wards have LSOAs that fall within the 20% most deprived for education skills and training (ONS 2010 Indices of Multiple Deprivation).	There are certain limitations as to how far the Site Allocations DPD could contribute to improving educational attainment in the borough since most of the schools to be built are primary schools and one secondary school. Land could be allocated for new schools to meet the demand of the growing population and the influx of new residents but the effects from such policy on the overall educational attainment would be minor positive since educational attainment is influenced by other factors. Opportunities with regards to educational attainment are more specifically addressed within the Suffolk Growth Strategy 2013 and the Site Allocations DPD will only have a supporting role in safeguarding land for educational use.
Human Health	Life expectancy from birth for males is slightly lower than the national average and life expectancy from birth for females is slightly higher than national averages. There is a need to reduce the incidence of diseases and health inequalities. Levels of teenage pregnancy are higher than regional and national levels and have implications for health service provision, housing and educational attainment. Alexandra, Westgate, Whitton, Gainsborough, Gipping and Stokes Park wards all have LSOAs within 20% of the most deprived for health deprivation and disability.	There are opportunities to improve the health of the Borough thorough the provision of new homes as there are links between the supply of decent housing and health. There are opportunities to provide recreational facilities which could improve levels of physical fitness. Opportunities should also be sought to encourage walking and cycling through the location and design of development.
Water	The key watercourses in the Borough are the River Gipping and Belstead Brook which both flow into the River Orwell. The Environment Agency has identified a risk of flooding on land adjacent to the Rivers Orwell, Gipping, Belstead Brook and Westerfield Watercourse. The East of England is the driest part of the country and the area is classed as being in ‘severe water stress’. Water supply is critically important, not only to agriculture but to some of the businesses currently located in Suffolk. Limited water availability and increasing demands means that much of the water resource in Suffolk is considered to be fully committed, if not overcommitted, to existing users (EA). Water quality is also a key sustainability issue. Most of the central and western area of Ipswich is designated as Source Protection Zone (SPZ) 2, with two smaller areas designated as SPZ1. SPZs are used to identify those areas close to drinking water sources, where the risk associated with groundwater contamination is greatest, and are important for identifying highly sensitive groundwater areas. SPZs are also recognised within the Environmental Permitting Regulations as a zone where certain development activities cannot take place.	The sustainability issues with regards to the SA topic Water are predominantly dealt with through policies included in the Core Strategy. Flood risk issues should be taken into consideration when allocating sites for development.
Soil and Land Quality	Much of Ipswich is an urban built up environment. There is some known potentially contaminated land within the Borough. In 2011/12, there was 67.2 hectares vacant or derelict land. (141.8 hectares total including sites in use, allocated or with planning permission) (Ipswich National Land Use database 2014).	Opportunities should be sought to include allotment space within the Borough where possible. Using brownfield land where possible should be encouraged. Any sites allocated for development which include potentially contaminated land should be remediated before re-use.
Air Quality	There are four Air Quality Management Areas (AQMAs) within the Ipswich Borough, all of which are designated for NO₂ exceedences. All of the AQMAs are located within central Ipswich.	Opportunities should be sought to promote the use of public transport, walking and cycling e.g. through the location of sites in areas already served by public transport or at distance from the main community facilities which will encourage sustainable modes of transport.
Climatic Factors	A number of areas within Ipswich lie within the floodplain. Largely these areas are associated with the River Gipping and River Orwell. There are also smaller watercourses at risk of flooding – Westerfield Watercourse and Belstead Brook. There are areas at risk of flooding, some from tidal surges and some from heavy rain. This risk may continue to grow as a result of rising sea levels and increasingly heavy rainstorms that can overwhelm drainage systems and cause localised flooding unless mitigation measures are implemented. The Ipswich Flood Defence Management Strategy is a major scheme to reduce flood risk to Ipswich over the coming years. The strategy was approved in March 2006 and recommends an investment in new flood defences across Ipswich to significantly reduce flood risk to over 3,000 residential properties. Half of the projects of the scheme have been completed with an expected date to deliver the final Tidal Barrier Project in 2017 (Environment Agency). In 2011, the estimate of CO₂ emissions for Ipswich was 4.2 tonnes per capita (Dept of Energy & Climate Change, 2011 data). When compared with CO₂ emissions per capita for Suffolk in 2009, Ipswich performed better (see Appendix B). There were no applications for renewable energy developments in 2013/14 (Ipswich Borough Council, 2014).	Flood risk issues should be taken into consideration when allocating sites for development and new development should be encouraged to use SuDS to manage runoff and further reduce flood risk on sites allocated within Flood Zones (particularly as some new development would be situated on previously undeveloped land).
Biodiversity, Flora and Fauna	There are three Sites of Special Scientific Interest (SSSI), one Special Protection Area (SPA), one Ramsar site, six Local Nature Reserves (LNR) and 19 County Wildlife Sites (CWS) within Ipswich (See Map 1 Sites of Ecological Importance). There is one area of ancient and semi-natural woodland along with ancient replanted woodland to the south of the Borough.	Development proposals should maximise opportunities to protect and enhance habitats and where appropriate create new habitats in order to deliver the biodiversity objectives of the relevant Biodiversity Action Plans (BAPs). When allocating sites for development, consideration should be given to the proximity of the development to the designated sites and the most appropriate use of the land.
Cultural Heritage	Ipswich is home to a wealth of heritage assets including those of a national and local importance. There are over 600 Listed Buildings, of which 11 are Grade I and 25 are Grade II*. There are ten Scheduled Ancient Monuments and 14 Conservation Areas (See Map 2 Cultural Heritage Assets). Several sites within Ipswich are listed on the Historic Environment Record.	It is important to ensure that the cultural heritage is protected and that cultural heritage issues are taken into consideration in allocating new sites for development. Cultural heritage features should be conserved and enhanced.
Landscape/ Townscape	The majority of Ipswich’s’ landscape typology is urban with some areas in the north located within ancient rolling farmlands and areas in the south east located within ancient rolling farmlands and rolling estate sandlands. The town centre has changed significantly during the twentieth century and although many historic buildings were lost to make way of new developments, it is a designated Conservation Area with historic and archaeological significance. In Ipswich there are over 600 Listed Buildings, of which 11 are Grade I and 31 are Grade II* (Ipswich Borough Council, Listed Buildings in Ipswich). Listed Buildings are largely concentrated within the town centre.	It is essential that landscape and townscape character and quality is enhanced through high quality design, careful siting, the incorporation of soft landscaping and attention to boundary treatments. In addition, when allocating sites for development it is important to maintain the gap between Ipswich and adjacent villages to preserve local distinctiveness.
Minerals and Waste	There are a number of waste facilities within the Borough, including, a household waste and recycling centre, a composting site and facilities for metal / end of life vehicles (not inclusive). In addition, an energy from waste incinerator is now operational at Great Blakenham (Masons Quarry) which lies approximately 3km north of the Borough boundary, therefore transport implications must be managed carefully. In 2012/13 40.8% of waste in Ipswich was recycled and composted (Ipswich Borough Council, September 2014). Reuse / recycling / composting rates were lower than those recorded for Suffolk, the East of England and England between 2008 and 2012.	Waste management issues are addressed through policies included in the Core Strategy (e.g. Policy CS4) and opportunities are identified in Table 3-2. Sites for waste management facilities are allocated through the Waste Core Strategy prepared by Suffolk County Council.
Transportation	The Borough is well connected by transport infrastructure and public transport links. The Ipswich Local Transport Plan includes a series of key priorities addressing transport and accessibility which include encouraging the provision and use of an integrated effective transport system which maximises the use of public transport, walking and cycling and reduces the overall impact of travel on the environment.	It will be important to ensure that new development can be easily accessed by public transport, cycling and walking through location of sites for development. It will be important to manage the additional travel demands that growth will generate and guide as many as possible to sustainable modes for the good of the environment, economy and health. The cycling and walking network within the Borough should be expanded and enhanced, particularly between the Waterfront and town centre.
Economy	Ipswich has a strong employment base for businesses with a slightly higher proportion than the Suffolk average of the population at the working age, but it also has a relatively higher proportion of people who are economically inactive. Employment in Ipswich exceeds the national profile in the finance, IT, transport, communications, and public administration education and health sectors. It is below the national profile in manufacturing. Ipswich has lower working age skills levels, especially at degree level (22.8%), than the county as a whole (24.4%). It is even further below the regional and national levels (29.9%) (State of Ipswich Report May 2011).A lower than average proportion of Ipswich’s population are classified as managers or senior officials while caring, leisure and other service occupations along with sales and customer service occupations and process plant and machine operatives are higher than regional and national averages. The Job Seekers Allowance rate in Ipswich (2011) is high compared to Suffolk and the national figures. It is particularly high for males, between the ages of 25-49 who have been unemployed for 6-months or over. The gross weekly pay for employees in Ipswich is lower than national and regional average (State of Ipswich 2014) and the Borough has higher numbers of people claiming benefits than county and national indicators suggest (2012-13). The factors restricting economic growth in Suffolk in general are a lack of qualified staff and poor broadband; as well as a lack of customers, transport links, and poor quality premises (Suffolk Growth Strategy).	Allocating enough good quality employment land to attract and retain jobs within the Borough is the main opportunity identified with regards to the SA topic. In addition, there are opportunities to attract private sector interest in the town to service and provide more opportunities for existing and new communities, such as more and better shops to enhance the high street. Allocating suitable and available sites for future town centre development to attract new investment in the centre without overstretching it is a key opportunity.
Deprivation and Living Environment	Gainsborough, Whitton, Whitehouse, Gipping, Stoke Park, Priory Heath, Bridge and Alexander wards all have LSOAs in the bottom 20% most deprived nationally (Index of Multiple Deprivation). Deprivation is a very complex issue and a number of different issues will need to be addressed for noticeable improvements to be realised. 30% of all the crime in Suffolk happens in Ipswich and 10% of all the crime in Suffolk happens in the Town Centre of Ipswich as a result of the night time economy. Ipswich also has the highest prevalence of organised crime in Suffolk including people trafficking, drug dealing and prostitution. Anti-social behaviour also forms a large percentage of crime incidents in Ipswich in June 2012. However, recorded crimes per 1000 of Ipswich’s population have fallen from 106 in 2008-2009 to 77 in 2013-2014.	There is a need to tackle anti-social behaviour and crime rates should be further reduced to enhance overall quality of life in Ipswich. This could be achieved through incorporating secured by design principles into new development and ensuring appropriate housing mixes are adopted. In addition, generally providing improved employment and educational opportunities for the local population could also contribute to (reduce) crime rates. Access to sports facilities should be enhanced. This could have associated health benefits.
Housing	Housing costs are relatively low but have gradually increased in recent years. Median house price (July 2013) in Ipswich is £150,000, which shows an increase of 7.1% from the median price of the same time the previous year (£140,000). The average house price is lower than Suffolk (£167,000 in July 2013) and lower than that in the East of England (£178,000 August 2013 – ONS). House prices have gradually increased but incomes have not matched this rate of growth, which may lead to problems of housing affordability. The affordability of purchased homes in 2011 was a ratio of 5:7 which was less than the affordability for Suffolk 6:9, the East of England 7:6 and England 6:5 (Office for National Statistics Local Profiles). 96 dwellings (net) were completed between 1st April 2012 and 31st March 2013, 7 of which were affordable housing completions (7.3%). 59 of these dwellings were on previously developed land (61.5%) and 17 were within the central IP-One area (17.7%). Gross housing completions (before calculating those dwellings lost) were 111 (AMR 2012-2013). The number of housing completions has fallen from a peak in 2007/08 as a result of the recession and lower demand for flats in this period. Completions for 2012/13 were at the lowest level in Ipswich since 1998/99 when 60 dwellings were completed. Affordable housing completions vary from year to year influenced by the availability of funding available and Ipswich Borough Council has commenced a programme of affordable house building across the borough with 108 dwellings to be built on a site at Bader Close in east Ipswich in addition to 7 dwellings completed on Coltsfoot Road and Whitton Church Lane. The Council’s adopted Core Strategy (2011) sets a target to allocate land to accommodate at least 14,000 additional residential units between 2001 and 2021 (700 dwellings p.a.). Housing delivery has averaged 653 p.a. April 2001 to March 2012. Completions peaked in 2007-08 but have fallen since then in line with the downturn and subsequent recession. The Strategic Housing Marketing Assessment 2008 which has further been updated in 2012 found there is a need for smaller one to two bedroomed homes in Ipswich to meet the needs of smaller households and an ageing population, as well as a continued need for smaller two to three bedroomed family homes. Much of recent housing development in Ipswich, however, has been in the form of one and two bedroomed apartments and in the present economic climate there is an oversupply of flats. 2.9% of all dwellings in Ipswich were vacant in 2011/12, representing a decrease from 3.3% in 2010/11. This figure is slightly lower than the Suffolk and England average although slightly higher than the East of England average. There are 972 vacant homes in Ipswich (2014), a decrease from 1,750 in 2011/12.	Allocating sufficient land to meet objectively assessed housing need in accordance with the Strategic Housing Marketing Assessment 2012 will be sought. Housing regeneration efforts present a significant opportunity both to revitalise the housing stock, address deprivation and to improve quality of life.

SA Topic

Key Sustainability Issues

Key Sustainability Opportunities

Population

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

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

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

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

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

There are opportunities to improve the supply of housing, education, health and other community facilities within the Borough through allocating sufficient land to meet objectively assessed housing need in accordance with the Strategic Housing Marketing Assessment 2012 and allocating land for community facilities.

Planning for a rise in the number of primary school age children is necessary, where appropriate, based on the level of forecast population growth and demand.

Additionally, supporting the completion of regeneration projects at the Waterfront would provide opportunities to address some issues relating to the provision of housing and community facilities.

Education and Qualifications

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

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

There are certain limitations as to how far the Site Allocations DPD could contribute to improving educational attainment in the borough since most of the schools to be built are primary schools and one secondary school. Land could be allocated for new schools to meet the demand of the growing population and the influx of new residents but the effects from such policy on the overall educational attainment would be minor positive since educational attainment is influenced by other factors.

Opportunities with regards to educational attainment are more specifically addressed within the Suffolk Growth Strategy 2013 and the Site Allocations DPD will only have a supporting role in safeguarding land for educational use.

Human Health

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

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

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

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

There are opportunities to provide recreational facilities which could improve levels of physical fitness. Opportunities should also be sought to encourage walking and cycling through the location and design of development.

Water

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

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

The East of England is the driest part of the country and the area is classed as being in ‘severe water stress’. Water supply is critically

important, not only to agriculture but to some of the businesses currently located in Suffolk. Limited water availability and increasing demands means that much of the water resource in Suffolk is considered to be fully committed, if not overcommitted, to existing users (EA).

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

The sustainability issues with regards to the SA topic Water are predominantly dealt with through policies included in the Core Strategy.

Flood risk issues should be taken into consideration when allocating sites for development.

Soil and Land Quality

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

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

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

Using brownfield land where possible should be encouraged. Any sites allocated for development which include potentially contaminated land should be remediated before re-use.

Air Quality

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

Opportunities should be sought to promote the use of public transport, walking and cycling e.g. through the location of sites in areas already served by public transport or at distance from the main community facilities which will encourage sustainable modes of transport.

Climatic Factors

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

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

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

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

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

Flood risk issues should be taken into consideration when allocating sites for development and new development should be encouraged to use SuDS to manage runoff and further reduce flood risk on sites allocated within Flood Zones (particularly as some new development would be situated on previously undeveloped land).

Biodiversity, Flora and Fauna

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

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

Development proposals should maximise opportunities to protect and enhance habitats and where appropriate create new habitats in order to deliver the biodiversity objectives of the relevant Biodiversity Action Plans (BAPs). When allocating sites for development, consideration should be given to the proximity of the development to the designated sites and the most appropriate use of the land.

Cultural Heritage

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

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

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

It is important to ensure that the cultural heritage is protected and that cultural heritage issues are taken into consideration in allocating new sites for development.

Cultural heritage features should be conserved and enhanced.

Landscape/ Townscape

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

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

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

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

In addition, when allocating sites for development it is important to maintain the gap between Ipswich and adjacent villages to preserve local distinctiveness.

Minerals and Waste

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

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

Waste management issues are addressed through policies included in the Core Strategy (e.g. Policy CS4) and opportunities are identified in Table 3-2.

Sites for waste management facilities are allocated through the Waste Core Strategy prepared by Suffolk County Council.

Transportation

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

It will be important to ensure that new development can be easily accessed by public transport, cycling and walking through location of sites for development.

It will be important to manage the additional travel demands that growth will generate and guide as many as possible to sustainable modes for the good of the environment, economy and health.

The cycling and walking network within the Borough should be expanded and enhanced, particularly between the Waterfront and town centre.

Economy

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

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

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

The gross weekly pay for employees in Ipswich is lower than national and regional average (State of Ipswich 2014) and the Borough has higher numbers of people claiming benefits than county and national indicators suggest (2012-13).

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

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

and poor quality premises (Suffolk Growth Strategy).

Allocating enough good quality employment land to attract and retain jobs within the Borough is the main opportunity identified with regards to the SA topic.

In addition, there are opportunities to attract private sector interest in the town to service and provide more opportunities for existing and new communities, such as more and better shops to enhance the high street.

Allocating suitable and available sites for future town centre development to attract new investment in the centre without overstretching it is a key opportunity.

Deprivation and Living Environment

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

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

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

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

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

Housing

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

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

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

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

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

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

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

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

Allocating sufficient land to meet objectively assessed housing need in accordance with the Strategic Housing Marketing Assessment 2012 will be sought.

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

The SA Framework

Background to the SA Framework

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

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

Development of the Sustainability Objectives

2.3.21 The Sustainability Objectives have been developed using the review of other relevant plans, programmes and environmental objectives, the baseline data and the key issues and opportunities. They were originally agreed in 2006 during the initial SA Scoping for Ipswich’s Local Plan and subsequently the SA of Ipswich’s now adopted Core Strategy DPD.

2.3.22 The SA Objectives have since been reviewed and have been slightly modified to reflect the requirements of the Site Allocations DPD and to take into account the consultation responses.

2.3.23 Table 2-3 presents the SA Objectives that were used in the assessment of the DPD and its options. Each of the Sustainability Objectives is supported by a series of SA Sub-Objectives and indicators to add further clarity and to assist the assessment process. As the SA process progresses, indicators and where appropriate, targets were developed to assist the assessment.

2.3.24 The purpose of identifying indicators in Table 2-3 is to enable the assessment to consider what effect a policy may have upon these indicators. Indicators proposed to monitor the significant effects of the plan are set out later in this report.

Table 2-3 The SA Framework

SA Objective		Sub-objectives	SA Indicator	Source
ET1	To improve air quality	Would the policy contribute to the protection and improvement of local air quality? Would the policy contribute to the impact of traffic congestion on air quality?	ET1a. Number and distribution of AQMAs ET1b. Exceedances of the annual average objective level for Nitrogen Dioxide in the AQMAs	Air Quality Archive Ipswich Borough Council
ET2	To conserve soil resources and quality	Would any new developments protect the land within the Borough from new contamination and exposure to existing contaminated land? Would new developments help to maintain and enhance soil quality where possible?	ET2a. Area of contaminated land returned to beneficial use ET2b. Density of new development ET2c. Amount (ha) of previously developed land available	Ipswich Borough Council Office for National Statistics (ONS) Department for Communities and Local Government
ET3	To reduce waste	Would the implementation of the policy increase the proportion of waste recycling and re-use? Would the implementation of the policy reduce the production of waste per capita? Would the implementation of the policies result in reduction of the proportion of waste landfilled? Would new developments encourage a reduced demand for raw materials? Would new developments promote the use of recycled and secondary materials in construction?	ET3a. Tonnage of household waste produced and recycled ET3b. Location and number of waste facilities serving the Borough ET3c. Amount of household waste collected per household	Defra Suffolk County Council
ET4	To reduce the effects of traffic upon the environment	Would the policy ensure that public transport services meet people’s needs i.e. through new bus services? Would the policy ensure that highways infrastructure meets people’s needs (including walking and cycling routes)? Would new developments promote the use of sustainable travel modes and reduce dependence on the private car?	ET4a. Traffic volumes, access to local services and journeys taken by sustainable modes ET4b. Journey to work by mode	Ipswich Borough Council 2001 and 2011 Census
ET5	To improve access to key services⁵ for all sectors of the population	Would new development maintain and improve access to essential services and facilities? Would new development improve access to open space?	ET5a. Proportion of new developments with access to key services by walking, cycling and public transport ET5b. Number of LSOAs with wards in bottom 10% of most deprived in terms of barriers to housing and services provision	Ipswich Borough Council www.communities.gov.uk
ET6	To limit and adapt to climate change	Would new developments contribute to a reduction in greenhouse gas emissions? Would new developments require the inclusion of SuDS? Would new developments reduce the demand for energy and increase energy efficiency? Would new developments increase the use of renewable energy? Would the policy contribute to a reduction in CO₂ emissions from the transport sector? Would new developments reduce and manage flooding?	ET6a. Total CO₂ emissions for the Borough ET6b. Annual average domestic gas and electricity consumption ET6c. Provision of shading and greening (i.e. avoiding the heat island effect)	ONS Department for Energy and Climate Change (DECC) Ipswich Borough Council
ET7	To protect and enhance the quality of water features and resources and reduce the risk of flooding	Would the policy ensure the protection and enhancement of ground and surface water quality? Would the policy encourage sustainable use of water resources? Would the policy encourage the inclusion of flood mitigation measures such as SuDS? Would new developments reduce and manage flooding?	ET7a. Water quality in rivers and groundwater quality ET7b. Daily domestic water use (per capita consumption, litres) ET7c. Number of planning applications granted permission contrary to Environment Agency advice	The Environment Agency Suffolk County Council Ipswich Borough Council
ET8	To conserve and enhance biodiversity and geodiversity , including favourable conditions on SSSIs, SPAs and SACs	Would the policy protect and enhance designated sites of nature conservation importance? Would the policy protect and enhance wildlife especially rare and endangered species? Would new developments protect and enhance habitats and wildlife corridors? Would new developments provide opportunities for people to access wildlife and open green spaces? Would new development protect and enhance geodiversity?	ET8a. Area (ha) of woodland ET8b. Extent and condition of key habitats for which Biodiversity Action Plans have been established ET8c. Number and distribution of designated sites including SPAs, Ramsar sites, Sites of Special Scientific Interest, National Nature Reserves, Local Nature Reserves and County Wildlife Sites and Regionally Importance Geodiversity Sites in Ipswich ET8d. Percentage of designated sites in favourable condition	www.magic.gov.uk Suffolk Biodiversity Action Plan Natural England GeoSuffolk website SBRC
ET9	To conserve and enhance the historic environment, heritage assets and their settings	Would the policy protect and enhance heritage assets and their setting? Would the policy contribute to the protection and enhancement of historic landscape / townscape value?	ET9a. Number of heritage assets ‘at risk’ ET9b. Number of listed buildings reviewed annually for condition, repair and ‘at risk’ status	English Heritage Ipswich Borough Council
ET10	To conserve and enhance the quality and local distinctiveness of landscapes and townscapes	Would new developments protect and enhance landscape character and quality? Would new developments protect and enhance townscape character and quality? Would new developments promote sensitive design in development? Would new developments promote local distinctiveness?	ET10a. Percentage of new housing completions achieving design standards such as Building for Life and Lifetime Homes	Ipswich Borough Council
HW1	To improve the health of those most in need	Would the implementation of the policy improve access to health and social care services? Would the policy contribute to a reduction in health inequalities amongst different groups in the community? Would new developments promote healthy lifestyles?	HW1a. Proportion of population with access to hospital / GP / Dentist HW1b. Proportion of journeys to work by foot or by bicycle HW1c. How children travel to school (Quality of Life Indicators (Government indicators) / Best Value Performance Indicators (Ipswich Borough Council) HW1d. Levels of physical activity data HW1e. Number of GP registrations for depression	Ipswich Borough Council 2001 and 2011 Census ONS
HW2	To improve the quality of life where people live and encourage community participation	Would new development encourage community participation? Would new development protect residential amenity from pollution? Would new developments minimise noise and light pollution?	HW2a. Play and open space quality, quantity and accessibility HW2b. Percentage of residents who are happy with their neighbourhood as a place to live (Place Survey) HW2c. Number of noise and light pollution complaints	Ipswich Borough Council Department for Communities and Local Government
ER1	To reduce poverty and social exclusion	Would the policy contribute to reduced overall levels of deprivation?	ER1a. Proportion of population who live in wards that rank within the 10% most deprived in the country ER1b. Provision of childcare	www.communities.gov.uk Ipswich Borough Council / Suffolk County Council
ER2	To offer everybody the opportunity for rewarding and satisfying employment	Would the policy contribute to a reduction in unemployment in the areas most at need? Would new developments improve physical accessibility to jobs for those in greatest need? Would the policy ensure people are educated, trained and skilled to meet local economic needs? Would the policy ensure labour supply meets local economic needs?	ER2a. Working age unemployment ER2b. Employment by occupation ER2c. Youth unemployment data ER2d. Long term unemployment data ER2e. Average wage data	ONS / National Online Manpower Information System (NOMIS) Ipswich Borough Council www.communities.gov.uk
ER3	To help meet the housing requirements for the whole community	Would the policy ensure that there is sufficient housing to meet identified needs in all areas? Would new developments ensure that housing meets acceptable standards? Would new developments increase the availability of affordable housing?	ER3a. Number of new dwellings completed in Ipswich including affordable housing ER3b. Percentage split of dwelling types ER3c. Average house price ER3d. Number of people presenting themselves as homeless.	Suffolk Observatory ONS Ipswich Borough Council
ER4	To achieve sustainable levels of prosperity and economic growth throughout the plan area	Would the policy encourage new business formation? Would the policy increase and diversify employment opportunities? Would the policy encourage economic growth? Would the policy ensure sufficient land, buildings and premises are available to accommodate business start-up and growth? Would the policy ensure Infrastructure (including transportation) meets the needs of business?	ER4a. Planning consents for employment uses ER4b Take up of employment land ER4c Population in Employment	Ipswich Borough Council (Monitoring reports) ONS – Nomis www.nomisweb.co.uk
ER5	To support vital and viable town, district and local centres	Would new developments maintain and improve access to shops, services and facilities in centres? Would new developments ensure a mix of retail units in centres?	ER5a. No. / Percentage of vacant retail units ER5b. Commercial / retail rental data ER5c Percentage of new retail floorspace developed within defined centres.	Ipswich Borough Council www.communities.gov.uk
ER6	To encourage efficient patterns of movement in support of economic growth	Would the policy ensure sufficient land, buildings and premises are available to accommodate business start-up and growth? Would the policy ensure Infrastructure (including transportation) meets the needs of business? Would the policy ensure that public transport services meet people’s needs i.e. through new bus services? Would the policy ensure that highways infrastructure meets people’s needs (including walking and cycling routes)? Would the policy promote the use of sustainable travel modes and reduce dependence on the private car? Would the policy reduce the impact of traffic on the economy?	ER6a No. / percentage of people working from home ER6b Waiting times at junctions in Ipswich See also ET4a (employment land take up) and HW1b (journey to work)	Ipswich Borough Council Suffolk County Council
ER7	To encourage and accommodate both indigenous and inward investment	Would the policy encourage inward investment and new business formation? Would the policy support the preservation and / or development of a high quality built environment? Would the policy promote the development of multi-functional green infrastructure in urban areas? Would the policy enhance the reputation of urban areas as places to live, work and visit?	ER7a. Business start-ups and closures ER7b. No. of business enquiries to Ipswich Borough Council / Suffolk County Council by types and size of site ER7c. Employment land availability	Ipswich Borough Council Suffolk County Council
CL1	To maintain and improve access to education and skills for both young people and adults	Would new development increase levels of participation and attainment in education for all members of society? Would new development improve access to and involvement in lifelong learning opportunities? Would new developments improve the provision of education and training facilities?	CL1a. GCSE Attainment Levels (Grades A*-C) CL1b. Proportion of the population with no qualifications	ONS www.communities.gov.uk
CD1	To minimise potential opportunities for crime and anti-social activity	Would the policy contribute to a reduction in crime levels? Would the policy contribute to a reduction in the fear of crime? Would the policy contribute to a reduction in levels of anti-social behaviour? Would new developments encourage secured by design?	CD1a. Recorded crime per 1,000 population CD1b. Burglary Rate CD1c. Fear of Crime (Quality of Life, Suffolk Speaks, British Crime Survey) CD1d. Number of domestic noise complaints	ONS www.communities.gov.uk Ipswich Borough Council

SA Objective Compatibility

2.3.24 The 21 SA Objectives have been tested against each other to identify any potential areas of internal incompatibility. The results are presented in Table 2-4 and summarised below.

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

ET1: ‘To improve air quality’
ET2: ‘To conserve soil resources and quality’
ET3: ‘To reduce waste’
ET4: ‘To reduce the effects of traffic upon the environment’
ET6: ‘To limit and adapt to climate change’
ET7: ‘To protect and enhance the quality of water features and resources and reduce the risk of flooding’
ET8: ‘To conserve and enhance biodiversity and geodiversity’
ET9: ‘To conserve and enhance the historic environment, heritage assets and their settings’
ET10: ‘To conserve and enhance the quality and local distinctiveness of landscapes and townscapes’

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

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

2.3.28 However, some of these uncertainties could be addressed through the production of SPDs, by requiring developments to meet Code for Sustainable Homes standards, promoting sustainable travel, and including measures to protect and enhance biodiversity.

The following notations are used in Table 2-4:

Objectives are compatible = +	No clear impact on each other = 0
Mutually incompatible = -	Compatibility unknown = ?

Table 2-4 Internal Compatibility of SA Objectives

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

SA Scoping Report

2.3.29 The SA process commenced in 2013 with the preparation of an SA Scoping Report for the Core Strategy Focused Review and the Site Allocations DPD (Hyder Report Reference: 001-UA006314-UE31-01). The Scoping Report was in two parts – Part One covered the Core Strategy and Part Two, the Site Allocations DPD. Part Two of the Scoping Report contained:

Characterisation of the environmental, social and economic baseline within the Ipswich area;
A review of relevant plans, programmes and environmental protection objectives that could influence the SA and the development of the Site Allocations DPD;
Identification of key sustainability issues and opportunities, together with recommendations for mitigation where required; and
Review of the SA Framework against which the policy changes of the Site Allocations DPD have been assessed.

2.3.30 In October 2013 consultation was undertaken on the scope of SAs for the Ipswich Site Allocations DPD and the Focused Review of the adopted Core Strategy. Whilst significant SA work has been undertaken on both plans since this time, the scope of these plans has since changed. A Scoping Letter updating the approach and scope of the SA was produced and consulted on in September 2014.

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

Geographical Scope of the Appraisal

2.3.32 The Scoping Report set out the scope and approach to the assessment of the Site Allocations DPD. The geographical scope of the SA has been driven by the geographical scope of the Site Allocations DPD. The Site Allocations DPD will apply to the whole of the Borough. The SA therefore considered the spatial extent of its likely impacts. In some cases, this may only be within the local area but in other cases, the impacts of the policies and site allocations may be felt over a wider area within the Borough or outside the Borough (i.e. in adjacent districts - Suffolk Coastal, Babergh and Mid Suffolk Local Authorities). Similarly, the cumulative effects of the policies may result in impacts occurring over a wider area (i.e. in-combination with other development across the Borough). This was also considered in the SA.

Temporal Scope of the Appraisal

2.3.33 The Site Allocations DPD sets out the framework for facilitating the determination of future planning applications within the Ipswich area until 2031.

Topics Covered in the Appraisal

2.3.34 The SA comprises the consideration of the environmental, social and economic effects of the Site Allocations DPD. The baseline characterisation has therefore reflected the topics set out in the SEA Directive, but also considers relevant additional social and economic topics as recommended in the PAS SA guidance. Table 2-5 identifies the topics covered, together with their relationship with the topics listed in Annex I of the SEA Directive.

Table 2-5 Topics Covered in the SA and Relevant SEA Directive Topics

Topics covered in the SA	Relevant topics listed in Annex I of the SEA Directive
Population	Population and Human Health Material Assets
Education and Qualifications	Material Assets
Health	Population and Human Health Material Assets
Crime	Population and Human Health
Water	Water and Soil
Soil and Land Quality	Water and Soil Material Assets
Air Quality	Air
Energy and Climate Change	Climatic Factors
Biodiversity, Flora and Fauna	Biodiversity, Flora and Fauna
Cultural Heritage	Cultural heritage and landscape
Landscape	Cultural heritage and landscape
Minerals and Waste	Material Assets
Transportation	Material Assets
Economy	Material Assets
Deprivation and Living Environment	Population and Human Health Material Assets
Housing	Material Assets

2.3.35 Annex I of the SEA Directive also requires an assessment of secondary, cumulative and synergistic effects, the results of which are provided in Chapter 4. Transboundary impacts on neighbouring authorities are considered inherently throughout the assessment.

Consultation

2.3.36 An SA Interim Report was issued for consultation from 13th January till 10th March 2014 alongside consultation on the Draft Site Allocations DPD. The consultation comments informed the next stage of the development of the DPD. Appendix C shows how the comments received have been responded to.

2.3.37 A Scoping Letter was issued for public consultation from 2^nd September to 7^th October 2014, for a five week consultation period. It was issued to the three statutory consultees (the Environment Agency, English Heritage and Natural England) and key stakeholders through the council’s website.

2.3.38 The aim of the scoping consultation was to obtain comment and feedback upon the scope and level of detail of the SA. The consultation comments have been considered and taken into account in the preparation of this SA Report. Appendix D presents the comments from the scoping consultation.

2.4 Stage B: Developing and Refining Options and Assessing Effects

Background to the Site Allocations DPD SA

2.4.1 SA has been an integral part of the evolution of the plan over time. The stages of development of the DPD and SA work is presented in Table 2-6 below.

Table 2-6 Background to the Site Allocations DPD SA

Year	Plan Document	SA Comments
2005-2007	Issues and Options	Consultation on the Issues and Options for both the Site Allocations and Policies DPD and IP-One Area Action Plan (AAP) was undertaken in January and February 2005. Further consultation was undertaken on specific sites and possible use options in June 2006. A final stage of Issues and Options consultation took place in February 2007 when further sites and possible options were put forward following them being suggested during the 2006 consultation.
November 2007	Preferred Options Site Allocations and Policies DPD	The combined SA (January 2008) assessed the options for the Site Allocations and IP-One AAP. The Preferred Options Site Allocations and Policies DPD did not contain a vision or objectives since these were contained within the Core Strategy document. It contained three Policy Areas which apply to sites or areas within the Borough of Ipswich but outside the IP-One AAP area. It also contained a series of proposed site allocations for different uses e.g. residential, office, etc. The Preferred Options Site Allocations and Policies DPD set out three policies that focus on sites that may be allocated for physical development, or retained for open space or nature conservation purposes. The Preferred Options IP-One AAP set out twenty four policies suggesting uses for identified land areas and site allocations in the town centre of Ipswich. Alternative policies were considered in both documents and were assessed against the SA Objectives.
November 2007	Preferred Options IP-One Area Action Plan
August 2012	The Preferred Options Site Allocations and Policies DPD and The Preferred Options IP-One Area Action Plan	The decision to combine the two plans was taken through the Council’s fifth revision of the Ipswich Local Development Scheme, which was brought into effect in August 2012
December 2013	Draft Site Allocations and Policies (Incorporating IP-One Area Action Plan) DPD	SA was undertaken of area-based policies, IP-One Policies, site allocations (including alternative site uses) and Opportunity areas. The SA comments related to consideration of alternative site uses are included in Appendix D of this report.
December 2014	Proposed Submission Site Allocations and Policies (Incorporating IP-One Area Action Plan) DPD	Review of the changes and update of the SA undertaken in 2013.

2.4.2 Assessing the Effects of the Site Allocations DPD

2.4.3 The following elements of the now combined Site Allocations and Policies DPD have been assessed in this SA:

Table 2-7 Elements of the Site Allocations and Policies DPD

Site Allocations
	SP1 The protection of allocated sites
	SP2 Land allocated for housing
	SP3 Land with planning permission or awaiting a Section 106 Agreement
	SP4 Land protected for Gypsy and Traveller sites
	SP5 Land allocated for employment use
	SP6 Land allocated and protected as open space
	SP7 Land allocated for leisure uses or community facilities
	SP8 Orwell Country Park Extension
	SP9 Safeguarding land on development sites for transport infrastructure
IP-One Area Policies
	SP10 Retail Site Allocations
	SP11 The Waterfront
	SP12 Education Quarter
	SP13 Ipswich Village
	SP14 Arts, Culture and Tourism
	SP15 Improving Pedestrian and Cycle Routes
	SP16 Transport Proposals in IP-One
	SP17 Town Centre Car Parking
IP-One Opportunity Areas
	A - Island Site
	B - Merchant Quarter
	C - Mint Quarter and surrounding area
	D - Education Quarter and surrounding area
	E - Westgate
	F - River and Princes Street Corridor

2.4.4 For the assessment of site allocations, the sites were grouped into 24 assessment groups. The grouping was based on geographical location and several sites in an area were grouped together. The groupings also took account of the Ipswich Area Committees. The groups included: Ipswich North West, Ipswich North East, Central, Ipswich South West, Ipswich South East and IP-One.

2.4.5 Each group of sites was assessed against the SA objectives in Appraisal Tables (Appendix F). One table was produced for each site assessment group, comparing each site allocation against each of the 21 SA Objectives topics. This approach provides a better understanding of the likely effects of the site allocations as the group of sites within an area can be considered together and will facilitate the assessment of cumulative impacts.

2.4.6 The detailed matrices determined significant impacts derived from the following:

Impact – whether the impact will be positive, negative or neutral when assessed against the SA Objectives.
Temporal scale – whether the impact will be short-term (within 5 years), occur in the medium term (5 – 10 years) or occur in the long-term (10 years +).
Spatial scale – whether the impact will be realised a local level or a Borough wide level. Any transboundary effects outside of the study area would also be considered.
Permanency – whether effects will be permanent or temporary.
Level of certainty – the level of uncertainty in the prediction will be classified as low, medium or high.

2.4.7 The sites, policies and opportunity areas were assessed against the SA Objectives and the matrix provides commentary and recommendations for further development. Notations used in the assessment are presented in Table 2-7 below.

Table 2-7 Notation used in the appraisals

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

2.4.8 The assessment of the Site Allocations DPD also made use of Geographical Information Systems (GIS) to identify the relationship between the DPD and the existing environmental and sustainability features, for example designated sites or areas of socio-economic deprivation.

2.4.9 The assessment made good use of the baseline data, which was updated during the assessment process. When assessing each element, the questions asked included:

To what extent does the policy/site allocation meet the SA Framework Objectives?
To what extent will the policy/site allocation seek to address sustainability problems?
To what extent will the policy/site allocation affect the current sustainability baseline conditions?

Mitigation Measures

2.4.10 Where appropriate, mitigation measures are recommended to avoid, reduce or offset the potential adverse impacts as a result of the Site Allocations DPD. In addition, potential opportunities to benefit and enhance the social, economic and environmental receptors are identified. Such recommendations have been presented to the plan-makers throughout the development of the plan and the SA. The matrices in Appendix F include the current remaining recommendations and references to other forms of mitigation that would need to be considered when bringing forward the sites.

Appraisal of Cumulative and Synergistic Effects

2.4.11 The SEA Directive requires inter alia that cumulative effects should be considered. It stipulates consideration of “the likely significant effects on the environment…” and that “These effects should include secondary, cumulative, synergistic…effects” (Annex I). The Practical Guide sets out the following definitions for these terms:

Secondary or indirect effects comprise effects which do not occur as a direct result of the proposed activities, but as a result of complex causal pathway (which may not be predictable).
Cumulative effects arise from a combination of two or more effects, for instance, where several developments each have insignificant effects but together have a significant effect; or where several individual effects of the plan or programme have a combined effect.
Synergistic effects – synergy occurs where the joint effect of two or more processes is greater than the sum of individual effects.

2.4.12 The potential for cumulative, synergistic or secondary or indirect effects as a result of the Site Allocations DPD has been inherently considered within the appraisal, the findings of which are presented in Section 4.6.

Appraisal of Transboundary Effects

2.4.13 The SEA Directive also requires SAs to consider the transboundary effects of the plan on other EU member states. These effects have been noted where appropriate throughout the assessment.

Technical Limitations and Uncertainties

2.4.14 During the assessment of the Site Allocations DPD, there has sometimes been uncertainty when predicting the potential effects. Where this has occurred, the uncertainty is identified within the appraisal matrices and accompanied by recommendations to preclude/mitigate any negative impacts.

2.4.15 In addition, a number of data gaps are identified within the baseline context where data is unavailable or out of date. Obtaining these datasets would help to further increase the knowledge of the areas, and could potentially be filled through the use of the monitoring framework.

2.4.16 Finally, the Site Allocations DPD essentially acts as a guidance document for the future development of Ipswich. There is therefore reliance upon future decision-makers to ensure sustainable development is ensured.

2.5 Stage C: Preparation of the SA Report

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

2.6 Stage D: Consultation on the Proposed Submission Draft Site Allocations and Policies Plan and the SA Report

2.6.1 This SA Report will be issued for consultation alongside Proposed Submission Draft Site Allocations DPD to all key stakeholders (including statutory consultees and the public) for comment. Following the close of the consultation period, IBC will review the feedback and revise the plan as appropriate.

² S.I. 2004 No. 1633: The Environmental Assessment of Plans and Programmes Regulations, 2004 ³ ODPM et al. (2005) A Practical Guide to the Strategic Environmental Assessment Directive ⁴ UK Sustainable Development Strategy: Securing the Future (2005) and the UK’s Shared Framework for Sustainable Development, One Future – Different Paths (2005) ⁵ District and/or Local centres have been used as a good indication of the location of services but it is noted that some services, particularly non-retail services, may also be provided outside of these locations.

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