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

Ended on the 5th March 2015
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Appendix C

Scoping Letter Comments

Summary of Comments and Responses received Jan-March 2014

Sustainability Appraisal Scoping Report Update Consultation (September/October 2014)

Summary of responses

Respondent

Summary of Response

IBC response

Suggested Action

Babergh District Council and Mid Suffolk District Council

No comments

Noted

No action needed

Natural England

Satisfied with the scope of the SAs as proposed.

Noted

No action needed

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

Noted

No action needed

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

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

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

English Heritage

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

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

No action needed

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

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

No action needed.

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

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

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

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

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

Scheduled Monuments will be added to the policies map and details of the relevant heritage assets will be referred to on the sites sheets which form part of the Site Allocations document. The SA of the Sites DPD will be accompanied by a constraints plan showing all known statutory heritage assets in Ipswich. The SA will also have regard to non-scheduled sites.

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

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

The sub-objective will be amended.

Anglian Water

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

Noted

No action needed

Northern Fringe Protection Group

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

The purpose of the SA is to assess the contents of the Core Strategy and Sites DPDs. The SA of the Core Strategy has not assumed vast numbers of jobs being created, it has reiterated the number of jobs that will be created in the borough over the plan period stated in the Core Strategy.

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

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

Environment Agency

No comments

Noted

No action needed

Save Our Country Spaces

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

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

No action needed

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

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

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

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

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

No action needed

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

Further consideration will be given to air quality effects arising from the Garden Suburb development.

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

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

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

A summary of the conclusions in the Draft Core Strategy and Policies Focused Review – Interim SA Report (December 2013) will be included within the updated SA of the Core Strategy.

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

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

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

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

Job forecasts are provided through the East of England Forecasting Model. The provision of homes to meet labour supply requirements is covered by the final sub-objective under SA objective ER2. However, whilst there is a link between number of jobs and provision of housing there is no simple ‘ratio’ that can be applied due to the multiple variables involved. The Core Strategy plans to meet both the land requirements of the jobs forecast and, as far as possible, the housing needs. The baseline of the SA identifies that Ipswich has lower than average salary levels.

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

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

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

The ‘Local Air Quality Management

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

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

The Draft Core Strategy and Policies Focused Review – Interim SA Report (December 2013) considered effects of 3,500 dwellings being provided at the Garden Suburb by 2031. ‘It is anticipated in the Supplementary Planning Document Interim Guidance (2014) that around 200 would be built per year from 2018’.

The SA will continue to consider the implications of all sites coming forward simultaneously.

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

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

No action needed.

Save Our Country Spaces

(received late)

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

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

No action needed.

Comments on Site Allocations Interim Sustainability Appraisal Report (December 2013)

Respondent Comments Response Action

Northern Fringe Protection Group

Against the existing Proposals map the proposed site allocations and proposals map shows the loss of designated countryside and conservation land off Tuddenham Rd in addition to the 3 Garden Suburb sites. The loss is unacceptable and unsustainable. No assessment of the increased traffic, increased coaches, impact on the humpback bridge and adjacent road without footway and rat running on Humber Doucy Lane has been made The SA should include an assessment of the change of use of the land; why has Hyder ignored this?

The assessment of the Proposed Submission Core Strategy will include an assessment of the proposed sports park area.

Amend SA of CS10 to include assessment of the sports park area.

Northern Fringe Protection Group

Concerned that Westgates has no potential occupier, suggest more residential development here, also at Grafton Way with hotel too and at Cox Lane/Tacket St which should have a mall linking Carr St and Upper Brook St and multi-storey car park. Need for long stay car park capacity is questioned, the issue is access and cost. Increased capacity is at odds with promoting walking/cycling/park&ride. Suggested to reopen Bury Rd P&R and make long term parking short term. SA should consider impact of more short journeys on air pollution and 3 sites reviewed in light of Bury Rd P&R reopening.

Grafton Way is subject to extant planning permission including 129 residential units. If this lapses, it is proposed to be allocated for residential use. The Westgate allocation is based upon the findings of the 2013 DTZ Town Centre Opportunity Areas report.

Policy SP9 safeguards the Bury Rd Park and Ride site for Park and Ride. SP17 focuses on provision of short stay parking. The SA has considered the implications of SP17.

None

Northern Fringe Protection Group

Policy CS17 deletes reference to Park & Ride assumed to be Bury Rd but site allocations DPD proposed extension of the facility and elsewhere in the plan there is commitment to re-opening the Park & Ride. If the P&R is not to be re-opened an alternative use for the site should be identified in the site allocations. Consistency is required across the whole document. Re-opening of the Park & Ride site is supported.

Policy SP9 now safeguards the Bury Rd site for Park and Ride.

None

Northern Fringe Protection Group

There is inconsistency over the density of Ipswich Sports Centre Hockey pitch site, an area of 0.6ha and 30 dwellings is shown and a requirement to meet the 35dph average in Policy DM30(c), but the allocation is for 50 dph. We believe 30 dwellings is unrealistic and out of character with the neighbourhood. The hockey pitch is classified as sport provision it would need to be replaced before change of use for housing could be sanctioned; current site access is also considered inadequate. The SA must take account of these issues and reassess accordingly.

DM30 provides an indication of average densities, however for allocated sites specific consideration has been given to the number of dwellings to be accommodated. The indicative capacity of the hockey club site (IP256) has been revised to 18 dwellings / 30dph.

None

Northern Fringe Protection Group

We believe the Council has an opportunity to improve amenity of sites near Cliff Quay for residential and employment users. The Council should aid the attractiveness of this site to developers by committing to working with Anglian Water to resolve the local odour issue. Further development in Ipswich risks worsening the problem. The SA should take account of this opportunity and recommend accordingly or if not Hyder should explain why this is not a good idea. We would like to see Hyder promote IBC generally committing to improving attractiveness of brownfield sites to developers.

Policy CS17 includes water management infrastructure within the list of key strategic infrastructure and a requirement for development to meet the on-site and off-site requirements.

The costs of remediating contamination on brownfield land are taken into account when requiring developer contributions. It is not possible for IBC to purchase and improve brownfield sites, which are largely in the ownership of private landowners.

None

Northern Fringe Protection Group

IP256 Artificial Hockey Pitch. There is an error in the table, which shows an area of 0.6ha, an allocation of 30 dwellings and a requirement to meet DM30c. The latter specifies an average density of 35dph whereas the allocation is for 50dph. It is unrealistic and contrary to Policy DM30c to build 30 units on this site. The development would be completely out of character with the surrounding housing, and the site access is inadequate. Under DM28 the pitch would require an alternative to be provided before a change of use for housing is granted. The SA needs amending accordingly.

DM30 provides an indication of average densities, however for allocated sites specific consideration has been given to the number of dwellings to be accommodated. The indicative capacity of the hockey club site (IP256) has been revised to 18 dwellings / 30dph.

None

Northern Fringe Protection Group

Table 4-6: The SA needs to recognise that the plan does little to improve educational standards in existing schools; little to tackle crime in existing wards, while promoting homes without jobs; little to improve health especially for those in poor housing stock; and nothing to redevelop/improve existing sub-standard housing. It uses obsolete jobs data and forecasts far exceed historic provision. Impacts on climate change will be negative and the potential sewage issues associated with growth have not been addressed. These omissions need to be rectified as a key objective.

Jobs are planned for in accordance with the EEFM forecasts. The 2013 EEFM data was not available at the time the SA was carried out. There is considered to be little significance between differences in the 2012 and 2013 forecasts.

Policy CS17 includes water management infrastructure within the list of key strategic infrastructure and a requirement for development to meet the on-site and off-site requirements.

The planning system has limited influence over existing stock, however it should not be assumed that new homes and jobs would only be occupied by new residents.

None

Northern Fringe Protection Group

Paragraph 4.4.2. The following recommendations are required: most recent population and employment data should be used and forecasts should be made across district boundaries; a firm jobs growth target will help focus delivery; a better balance between new jobs and homes is needed with homes built near jobs; less reliance on retail growth and better alignment with NALEP growth sectors; a PDL target should be reintroduced; water supply and sewerage should be addressed; and more should be done to improve the lives of existing residents.

The EEFM forecasts are also produced for neighbouring authority areas. It should not be assumed that residents of new homes would only occupy ‘new’ jobs, consideration should also be given to the location of existing jobs. The NALEP growth sectors are referred to in relation to CS13 and the NALEP Plan is identified in the list of baseline information which has informed the development of the sustainability objectives. Due to the limited availability of land within Ipswich a PDL target would not be appropriate.

None

Barton Wilmore

Objects to the assessment which concludes development would increase run off; there is no evidence for this. Any application would include a flood risk analysis and ecological appraisal to avoid adverse impacts. Also objects to the conclusion that development would have a significant impact on biodiversity and soil quality and would mean the loss of agricultural land. The Phase 1 habitats survey by SWT shows subject to mitigation impacts are acceptable. The loss of food growing land is not significant and the land has not been used for arable agriculture for some years.

This relates to IP140. The SA assesses the site allocation on its own and the score relates to the ‘without mitigation’ effects. It is acknowledged that applications would consider flood risk and this is reflected in the mitigation measure identified. The development of the greenfield site would lead to a degree of loss of agricultural land even if not currently used for agriculture. In relation to important biodiversity features, mitigation measures are identified to mitigate any potential effects.

None

GeoSuffolk

Policy DM31 Conserving Local Natural and Geological Interest
9.167 should read
‘CGS are County Geodiversity Sites, designated on the basis of locally developed criteria. They are the most important sites for geology and geomorphology outside statutorily protected sites such as SSSIs. GeoSuffolk has so far registered three sites within in Ipswich: at Holywells Park (under an earlier RIGS - Regionally Important Geological and Geomorphological Sites - designation), at Christchurch Park (CGS) and Sarsenstones at Stoke Bridge Pocket Park (CGS).’

Further information in relation to CGS has been added to 9.195.

Further information in relation to CGS has been added to 9.195.

Environment Agency

We largely agree with the findings in the SA Report on matters relating to flood risk and land contamination, in particular opportunities arising out of development proposals to improve soil resources for the latter.

Noted

None

Natural England

We are reasonably satisfied that the Interim SA considers the impacts of the Site Allocations DPD on relevant aspects of the environment within our remit. We particularly welcome SA objectives to protect/enhance designated sites and non-designated areas of biodiversity. However, there are areas where the assessment does not fully address potential biodiversity impacts and mitigation requirements. The SA identifies some allocations with potential to adversely affect biodiversity. 4.4.2 includes mitigation recommendations which should be included in the DPD. Section 4.4.2 should also include a recommendation requiring that all proposals be subject to at least a desk top ecological assessment.

An Annex has been produced by Ipswich Borough Council which shows how the mitigation measures have been incorporated in the production of the Site Allocations DPD. DM31 has been revised in collaboration with Natural England.

An Annex has been produced by Ipswich Borough Council which shows how the mitigation measures have been incorporated in the production of the Site Allocations DPD.

Natural England

With regard to the IP149 Pond Hall Carr and Farm allocation the SA only identifies positive outcomes for biodiversity. Whilst recognising the proximity of the site to the Stour and Orwell Estuaries SPA and Ramsar the SA fails to acknowledge the potential for the allocation to have an adverse effect on this European site through increased recreational disturbance, as identified through the AA. Natural England advises that the AA be amended in accordance with our comments above and the revised conclusions and recommendations of the AA should then be included in the SA and Policy DM44 of the DPD.

It is agreed that the potential negative effects should be acknowledged.

Amend assessment of IP149 to reflect potential negative effects.

English Heritage

It is noted that the SA recommends that relevant policies and sites require new developments to be sensitive to heritage assets (e.g. paras 4.4.2, 4.5.62,.4.6.62) and we hope this recommendation can be implemented. Appendices F and G contain specific wording for individual sites in terms of heritage issues (e.g. IP172)which offer a starting point for setting out development criteria for sites. As with the main consultation document, the SA appears to overlook scheduled monument issues.

It is agreed that further consideration should be given to impacts on Scheduled Monuments.

Further reference to archaeology has been added into the Site Sheets where relevant and the SA of individual sites has identified the existence of Scheduled Monuments where relevant.

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