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

3. APPRAISAL OF THE ALTERNATIVES

3.1 Alternative Vision and Objectives

3.1.1 The Core Strategy vision and objectives provide the context for the Site Allocations DPD. The Preferred Options Site Allocations and Policies DPD produced in 2007 does not contain a vision or objectives. However, the IP-One Area Action Plan provided a vision and objectives, which were assessed in the Complete Preferred Options SA (2007). The Proposed Submission Site Allocations and Policies DPD (2014) does not present alternative vision or objectives as these are contained within the Core Strategy DPD. As such, no alternative visions or objectives have been assessed.

3.2 Alternative Policies

Background to the Assessment of Alternative Policies

3.2.1 Alternative policies relating to site allocations were assessed in the Preferred Options SA in 2008. 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 Area Action Plan set out twenty four policies suggesting uses for identified land areas and site allocations in the town centre of Ipswich.

3.2.2 Alternative policies were considered in both documents and were assessed against the SA Objectives. The document covers a number of alternative options which were considered alongside the chosen one. The policies and their alternatives were assessed against the 22 SA objectives using a scoring system. Of the three policy areas, the preferred options scored better in terms of sustainability on two. One policy (policy area 39) could not be scored since it was seeking to reserve the sites proposed to the uses allocated to them and therefore the impact would vary from site to site.

Appraisal of the ‘No Policy’ / ‘Business as Usual’ Option

3.2.3 An option representing a ‘No Policy’ / ‘Business as Usual’ approach was subject to the SA process as the comparison of options to a ‘Business as Usual’ situation is a requirement of the SEA Directive. New policies added in the Proposed Submission Site Allocations DPD also include ‘no policy’ alternative (Appendix E).

3.2.4 In the absence of the policies, there is likely to be much greater uncertainty over requirements that proposals for new development will need to address.Whilst the Core Strategy would provide a significant strategic guidance to development across the Borough, there is a need to ensure that policy is consistent and up to date as a whole and for individual sites to provide certainty about micro-setting, the scale or form of development, energy and materials use, the appearance of structures, access to sustainable transport, the impact on local environmental and built heritage features amongst a number of other issues. In particular, without a consistent set of planning guidance in this form, there would be a greater likelihood of a number of smaller adverse effects occurring which could lead to greater overall cumulative effects.

3.2.5 In the absence of the policies, there would be less guidance on the way town centre areas should be developed or regenerated to meet identified needs, or on measures to help improve the sustainable access to community facilities. This a ‘lost opportunity’ type alternative and no policies in place would mean not planning in comprehensive manner to alleviate problems in the area. Consequently a list of policies are being produced in order to provide greater certainty and direction in a coordinated manner.

3.3 Alternative Site Allocations

3.3.1 Given the limited availability of development land within Ipswich, the Council allocated for development all the sites believed to be suitable and deliverable, in order to comply with the NPPF requirement to meet the objectively assessed housing need. As such, there were no other reasonable alternative sites. Throughout the process of assessing the deliverability, the following constraints were considered:

• Access and Highways

• AQMA within or close to

• Area of Archaeological Importance

• Conservation Areas

• Contaminated Land

• Existing Use

• Flood Zone 2 and 3

• Listed Buildings on site or nearby

• Recreation and Open Space

• Tree Preservation Order (TPO) on site or nearby

• Wildlife site or adjacent to

• Noise

3.3.2 Since the Preferred Options SA prepared in 2007, some sites that were included in the Preferred Options Document have been discounted in the Site Allocations DPD. The discounted sites are listed in Section 5 of the SHLAA Update Report (November 2013) along with the reasons for not taking the sites forward at this stage of the plan. In addition to the sites listed in SHLAA, two more sites (IP175 and IP261) have since been discounted. The main reasons for discounting sites are related to:

• uncertainty with regard to the deliverability of the site within the plan period

• changed circumstances of existing use (when potential development is subject to relocation of existing uses on site)

• development of the site has been completed

• viability issues associated with amenity concerns, access and flood risk

3.3.3 The discounted sites are considered unreasonable alternatives therefore no further SA of their allocation was undertaken.

3.3.4 A high-level assessment of alternative uses of the selected sites was undertaken in December 2013 (Appendix D Report 003-UA006314-UE31-01). Alternative uses identified for each proposed allocation were compared with reference to their contribution to or impact on the SA Objectives. IP150c Land south of Ravenswood has changed from a housing allocation to employment to support the economy.