Sustainability Appraisal Scoping Report

Ended on the 30 October 2017

(4) Non-Technical Summary


This Non-Technical Summary (NTS) provides an outline of the Scoping Report produced as part of the Sustainability Appraisal (SA) of the Ipswich Local Plan 2016–2036 which is currently being prepared by Ipswich Borough Council (IBC).  IBC is aligning its Local Plan with Babergh District, Mid-Suffolk District and Suffolk Coastal District – the other authorities which form the Ipswich Housing Market Area and Ipswich Functional Economic Area.

SA appraises the environmental, social and economic performance of the Local Plan and any reasonable alternatives, helping to ensure its contribution towards sustainability.

The Scoping Report sets out the proposed approach to undertaking the SA of the emerging Local Plan. It provides an opportunity for statutory consultees (Natural England, the Environment Agency and Historic England) as well as other bodies, local authorities and the public, to comment on the scope of the SA and the level of detail that should be included within the appraisal.

This NTS will:

  • Explain the context to the Ipswich Local Plan 2016-2036;
  • Explain the SA process and how this is used in developing the Local Plan;
  • Give an overview of the key economic, social and environmental issues relevant to SA of the Local Plan;
  • Describe the proposed approach to undertaking the appraisal of the Local Plan;
  • Explain the next steps in the SA process; and
  • Detail how you can respond to consultation on the Scoping Report.

Ipswich Local Plan

The emerging Local Plan will help to shape the future growth and development of the district and the economic, social and environmental relationships between the Ipswich Housing Market Area authorities.

The 2016-2036 Local Plan will replace the existing 2017 Ipswich Local Plan Documents, which cover the plan period 2011-2031, namely:

  • Core Strategy and Policies DPD Review (adopted February 2017)
  • Site Allocations and Policies (incorporating IP-One Area Action Plan) DPD (adopted February 2017)

Table A – Ipswich Borough Council Key Facts

Ipswich Borough Council Local Plan - Key Facts

Name of Responsible Authority

Ipswich Borough Council

Title of programme

Ipswich Borough Council Local Plan

What prompted the plan

The Council adopted its Local Plan in February 2017 for the period 2011 to 2031. The Inspector's report on the examination of that plan concluded it is now necessary to produce joint or aligned Local Plans (with Babergh, Mid Suffolk and Suffolk Coastal District Councils), to consider future housing or employment development within the Ipswich Housing Market Area and Ipswich Functional Economic Area. 


Spatial development planning

Period covered

2016 to 2036

Frequency of updates

As needed in order to keep the plan up-to-date.

Area covered

The administrative area of Ipswich Borough Council as part of the wider Ipswich Housing Market Area

Purpose and scope of the plan

To succeed the adopted Ipswich Local Plan (2017) in being the adopted development plan for the Borough to 2036. To address strategic and local planning matters in the context of the Borough and the wider Ipswich Housing Market Area and Functional Economic Area. In line with the National Planning Policy Framework, to meet the objectively assessed housing needs of the housing market area in full, in alignment with Babergh, Mid Suffolk and Suffolk Coastal Districts which also form the housing market area.

Contact point

Planning Policy Team

Planning and Development, Ipswich Borough Council, Grafton House

15-17 Russell Road, Ipswich, IP1 2DE

Tel:  01473 432019

This Sustainability Appraisal Scoping Report accompanies the Local Plan Issues and Options Consultation, which is the first stage in the process of developing a Local Plan.  It will be followed by further periods of consultation and engagement with the general public and interested stakeholders as detailed in the Local Development Scheme[1].

Further opportunities to have your say are scheduled to arise in 2018:

  • First draft plan – spring 2018 (regulation 18)
  • Final draft plan – autumn 2018 (regulation 19)

What is Sustainability Appraisal?

The National Planning Policy Framework states that local plans are critical to delivering sustainable development and that they must be prepared with the objective of contributing to the achievement of sustainable development.

A Sustainability Appraisal (SA) is a systematic process by which the Local Plan is assessed to see how well it meets the economic, social and environmental needs of its current and future population.  Sustainable development is defined "development that meets the needs of the present without compromising the ability of future generations to meet their own needs."

The SA evaluates alternative spatial development proposals and scenarios and considers their relative merits against each other in order to take forward the most appropriate policy approaches in the Local Plan.  The SA also incorporates a process set out under a European Directive and related UK regulations called Strategic Environmental Assessment (SEA). It also examines the consequences of not developing a new Local Plan.  This SA will be specific to Ipswich Borough, taking into account Ipswich's position within the wider Ipswich Housing Market Area and Functional Economic Area (see figure A, below).

Figure A. Ipswich Housing Market Area

There are five key stages in the SA process which are shown in Figure B.

We are here

Figure B: Local Plan and Sustainability Appraisal Process

This report is the Scoping Report required in Stage A of the SA.  It comprises five tasks:

  1. Review of relevant policies, plans, programmes and strategies  – See Chapter 2
  2. Collation and analysis of baseline information – See Chapter 3 and then:
    1. Social baseline – Chapter 4
    2. Environmental baseline – Chapter 5
    3. Economic baseline – Chapter 6
  3. Identification of key sustainability issues – Chapter 7
  4. Development of the SA Framework – Chapter 8
  5. Consultation on the scope of the appraisal as presented in this report – Chapter 9.

Tasks 1 and 2 allow the identification of key sustainability issues.  This in turn informs task 4, the proposed SA Framework, which will be used to appraise the effects of the Local Plan (and any reasonable alternatives). Task 5 gives stakeholders and opportunity to provide comments and feedback on the Scoping Report and the SA Framework will be amended to take into account consultation responses as appropriate.  This will form the revised SA Framework.

The revised SA Framework will be then be used to appraise the effects of the emerging Local Plan (Stage B), as the Local Plan goes through various stages of preparation and consultation.  At each consultation stage for the Local Plan, interim SA reports will be provided and a final SA Report that will accompany the submission draft Local Plan (Stage C). This, alongside the Local Plan, will be examined by an independent planning inspector at an Examination in Public (Stage D).

Following Examination in Public, the Council will issue a Post Adoption Statement which will set out the results of the consultation and SA processes and the extent to which the findings of the SA have been accommodated in the adopted Local Plan. If the inspector requires any significant changes to the draft Local Plan they may require appraisal before this stage is reached.

The Council will monitor the implementation of the Local Plan continually during its lifetime and the Annual Monitoring Report will report any significant social, economic and environmental effects (Stage E).

The Key Sustainability Issues for the Ipswich Local Plan

Having reviewed the plans and programmes and analysed the baseline information, fifteen key sustainability issues relevant to the Local Plan have been identified and are set out in the table below. 

Table A – Sustainability Issues relevant to the Ipswich Local Plan

Key SA issue across Ipswich and Suffolk Coastal

Ipswich Borough Specific Issues


The need to reduce inequality and social exclusion

Ipswich scores worse than the Suffolk average against every indicator the 'Index of Multiple Deprivation Score' except, barriers to housing and services. 

One in five children in Ipswich lives in poverty.

High comparative  level of teenage pregnancy

Impact of changing demographics and migration trends

The Borough, compared to the rest of the county has a higher number of children, a higher population of working age because of the availability of job opportunities.

Although there is an aging population, there is a trend to retire out to rural areas.

Ipswich expects to see more births than deaths across the decade, 2014-2024.


The need to ensure the delivery of a sustainable supply of housing

Limited land availability and large areas of protected land.

Over the last two years house sales have fallen by 50% in Ipswich.

Ensuring the delivery of  mix of housing types and tenures (including affordable housing)

Low comparative level of owner occupiers with no mortgage, higher socially rented stock and higher private rental sector.

Ipswich has the lowest house price to income ratio in the IHMA.  Homes cost on average 6.44 times average income.  However prices have risen significantly in the last few years and Ipswich has the highest affordable housing need.

Need to deliver a more diverse range of housing types.

The impact of a changing population on housing supply. Increased demand for specialist housing including student accommodation.

Health and Wellbeing

The need to ensure the delivery of health and social care provision in line with growth

Population is younger than the county, regional and national averages.

Requirement to retain and improve existing community health facilities and services and ensure the timely delivery of new facilities to meet needs arising from new development

The need to address health inequalities and public health

Gypsies and Travellers experience some of the worst health in all BME groups.

Ipswich has proportionally more 0-5 year olds than other districts

Promoting healthy lifestyles

Ipswich has the lowest levels of physical activity in the region

Crime rates and anti-social behaviour

Ipswich had the highest number of criminal offences committed in 2013 in the IHMA.

Addressing fear of crime.


The need to ensure the delivery of education provision in line with growth

Insufficient primary and secondary capacity in some areas of the Borough.

The need to ensure appropriate skills to match future employment needs

Overall in comparison with the rest of the region and Britain, Ipswich had lower levels of qualified people at all levels in 2015.


Managing water resources and water quality

There are a number of Groundwater Source Protection Zones in Ipswich.

High number of existing groundwater and surface water Nitrate Vulnerable Zones.

The timely provision of new water services infrastructure in line with growth

The timely provision of new water services infrastructure in line with growth


Improving air quality

Congestion at various locations in the town centre and associated air quality issues

There are currently four Air Quality Management Areas in Ipswich

The requirement for clean vehicle infrastructure to encourage uptake of technologies

The requirement for clean vehicle infrastructure to encourage uptake of technologies

Material Assets (including soil and waste)

The need to maintain and/or enhance soil quality

The need to remediate contaminated sites and avoid contamination.

Very little high quality agricultural land remaining.

The need to manage waste arisings in accordance with the waste hierarchy

The need to manage waste arisings in accordance with the waste hierarchy

The need to encourage development on previously developed land and/or make use of existing buildings and infrastructure

The average percentage of housing built on previously developed land in Ipswich from 2001/02 to 2013/14 was 92.9%.

The need to protect and enhance sites designated for their geological interest

The need to protect and enhance sites designated for their geological interest

Climatic Change

The need to ensure that the built environment adapts to the impact of climate change and extreme weather events

The need to increase renewable energy provision and deliver carbon neutral development.

The need to ensure sustainable construction techniques and green infrastructure are employed to mitigate climate change and address fuel poverty.

The need to address pluvial, fluvial and coastal flood risk

Ipswich has a Flood Defence Management Strategy including a tidal surge barrier which will be completed this year.

The Coast and Estuaries

The need to manage pressure on protected sites

Large areas protected for species and habitat value which come under pressure from increased recreational and tourist activity


The need to conserve and enhance biodiversity (including sites designated for the their nature conservation value)

Numerous protected species, habitats and sites across the borough and pressures on climate biodiversity arising from climate change and urban development.

Need to extend and enhance the green infrastructure network across the whole IHMA.

The need to halt biodiversity net loss

High biodiversity value.

Cultural Heritage

Maintaining and enhancing designated and non-designated heritage and cultural assets

High number of heritage assets.


The need to ensure the protection and enhancement of local distinctiveness and character

Managing development while protecting significant areas of environmental protection.

Delivering high quality design that respects local character.

The need to manage pressure from new development on the AONB

Some AONB areas in Ipswich.


The need to support and maintain a sustainable local economy

Competition for land from housing.

Full-time female workers earn a third less than full-time male workers in Ipswich.

Promoting growth in key employment sectors.

Enhancing town and service centres and their role

Changing nature of the high street, local and district centres and changing shopping habits.

Transport and connectivity

Reducing the need to travel

Co-location of services.

Encouraging the use of sustainable transport modes

Improving the walking and cycling environment, lack of integrated public transport and relatively cheap car parking.

Provision of adequate public transport infrastructure

Digital Infrastructure

The need to realise opportunities for social inclusion through the provision of improved online services

Access to fast broadband and wifi across the town.

Unreliable mobile phone coverage in some areas.

The need to support the growth of the digital economy

Access to fast broadband and wifi across the town.

These sustainability issues, in turn, inform the proposed SA Framework.

What is the Proposed SA Framework?

At the centre of the SA process, and what the scoping report identifies, is the framework for the SA.  The framework comprises objectives, guide question and related indicators which have been developed to enable the Council to consider the impacts and alternatives of plans, programmes and policies.

The Objectives, guide questions and indicators in Table C, overleaf, are common across Ipswich and Suffolk Coastal. The Babergh/Mid Suffolk SA Framework was developed at an earlier stage, but is reflected in IBC/SCDC framework. Any differences in the framework are shown highlighted in yellow and the equivalent Babergh/Mid Suffolk objective number is shown in brackets after each objective.

Table C – Sustainability Appraisal Framework

SA Objective

Guide Question


Topic in the SEA Directive


1. To reduce poverty and social exclusion (3[2])

  • Will it reduce poverty and social exclusion in those areas most affected?
  • Will it reduce benefit dependency?[3]
  • Does it support the changing population profile of the area?
  • Will it encourage engagement/participation in community/cultural activities?
  • Will it contribute to regeneration activities?
  • Will it enhance the public realm?
  • Long term unemployment rate (Suffolk Observatory)
  • Proportion of the population who live in wards that rank within the most deprived 10% and 25% of wards in the country (Index of Multiple Deprivation)

  • Human health
  • Population


2. To meet the housing requirements of the whole community (5)

  • Will it contribute to the supply of housing?
  • Will it reduce homelessness?
  • Will it contribute to meeting demand for a range and mix of housing including affordable housing and specialist housing?
  • Will it reduce the number of unfit homes?
  • Will it contribute to the delivery of sustainable homes?
  • New homes completed in the monitoring year (council records)
  • New homes approved in the monitoring year (council records)
  • Recorded homeless rates (ONS)
  • Net additional dwellings – size, type, affordable (Council records)
  • Human health
  • Population
  • Material assets

Health and Wellbeing

3. To improve the health of the population overall and reduce health inequalities (1)

4. To improve the quality of where people live and work (4)

  • Will it improve access to health facilities and social care services?
  • Will it encourage healthy lifestyles?
  • Will it support the diverse range of health needs within the community?
  • Will it contribute to a healthy living environment? (noise, odour etc?)
  • Will it reduce crime/ fear of crime and anti-social activity?
  • Will it promote design that discourages crime?
  • Will lit avoid locating development in locations that could adversely affect people's health?
  • Will it support those with disabilities?
  • Condition of residents general health (Census - QS302EW)
  • Change in the amount of Accessible Natural Greenspace (Natural England)
  • Level of recorded crime and anti-social behaviour (Suffolk Observatory)
  • Water
  • Climate factor
  • Human health
  • Fauna
  • Biodiversity
  • Flora


5. To improve levels of education and skills in the population overall (2)

  • Will it improve qualifications and skills of young people and adults?
  • Will it support the provision of an adequate range of educational and child care facilities?
  • GCSE and equivalent results for young people (Department for Education)
  • % of working age population with NVQ level 4+ or equivalent qualification (Census 2011 - QS501EW)
  • Population
  • Human health


6. To conserve and enhance water quality and resources (6)

  • Will it support the achievement of Water Framework Directive Targets
  • Will it protect and improve the quality of inland waters?
  • Will it protect and improve the quality of coastal waters?
  • Will it promote sustainable use of water?
  • Will it maintain water availability of water dependent habitats?
  • Will it support the provision of sufficient water supply and treatment infrastructure in a timely manner to support new development?
  • Will it improve ground water quality?
  • Recorded water quality in rivers, estuaries and groundwater
  • from River Basin Management Plans (Environment Agency)
  • Recorded Water Resource Availability Status (Environment Agency, Anglian Water, Essex & Suffolk Water)
  • Bathing water quality (EA)
  • Soil
  • Material Assets
  • Landscape
  • Flora


7. To maintain and where possible improve air quality (7)

  • Will it protect and improve air quality?
  • Will it avoid exacerbating existing air quality issues in designated AQMAs?
  • Number of designated AQMAs (Council records)
  • Estimated district CO2 emissions (Department of Energy and Climate Change)
  • Air
  • Human health
  • Fauna

Material Assets (including Soil)

8. To conserve and enhance soil and mineral resources (8)

9. To promote the sustainable management of waste (9)

  • Will it encourage the efficient use of land?
  • Will it minimise the loss of open countryside to development?
  • Will it minimise loss of the best and most versatile agricultural land to development?
  • Will it maintain and enhance soil quality?
  • Will it promote sustainable use of minerals?
  • Will it encourage the use of previously developed land and/or the reuse of existing buildings?
  • Will it prevent land contamination and facilitate remediation of contaminated sites?
  • Will it reduce household waste generated/ head of population?
  • Will it reduce commercial and industrial waste generated/ head of population?
  • Will it increase rate/head of population of waste reuse and recycling?
  • Percentage of development recorded on greenfield / brownfield land (Council records)
  • Change in recorded soil quality (Environment Agency)
  • Allocations recorded on best agricultural land quality (1,2,3) (Council records/DEFRA)
  • Estimated household waste produced (Council records)
  • Estimated quantity of household waste recycled (Council records)
  • Human health
  • Landscape

Climatic Change and flooding

10. To reduce emissions of greenhouse gases from energy consumption (10)

11. To reduce vulnerability to climatic events and flooding (11)

  • Will it ensure suitable adaptation to climate change?
  • Will it reduce emission of greenhouse gases/head of population by reducing energy consumption?
  • Will it increase the proportion of energy needs being met by renewable sources?
  • Will it minimise the risk of flooding from rivers and watercourses?
  • Will it minimise the risk of flooding on the coasts/estuaries?
  • Will it reduce the risk of coastal/ estuarine erosion?
  • Will it reduce the risk of damage from extreme weather events?
  • Estimated district CO2 emissions (Department of Energy and Climate Change)
  • Installed MWs of commercial scale renewable energy schemes (Council records)
  • Estimated number of properties at risk from flooding (Environment Agency)
  • Number of schemes incorporating SUDs mechanisms (Suffolk County Council)
  • Biodiversity
  • Flora
  • Fauna
  • Cultural heritage including architectural & archaeological heritage
  • Landscape

The Coast and Estuaries

12. To safeguard the integrity of the coast and estuaries  (-)

  • Will it support sustainable tourism?
  • Will protect environmentally designated sites?
  • Will it protect the special character and setting of the coast and estuaries?
  • Recorded visitor numbers on designated European sites (AONB unit, Natural England, Council records)
  • Biodiversity
  • Flora
  • Fauna
  • Landscape
  • Water


13. To conserve and enhance biodiversity and geodiversity (12)

  • Will it maintain and enhance European designated nature conservation sites?
  • Will it maintain and enhance nationally designated nature conservation sites?
  • Will it maintain and enhance locally designated nature conservation sites?
  • Will it avoid disturbance or damage to protected species and their habitats?
  • Will it help deliver the targets and actions in the Biodiversity Action Plan?
  • Will it help to reverse the national decline in at risk species?
  • Will it protect and enhance sites, features and areas of geological value in both urban and rural areas?
  • Will it lead to the creation of new habitat?
  • Change in the number and area of designated ecological sites (Natural England)
  • Recorded condition/status of designated ecological sites (Natural England)
  • Recorded visitor numbers on designated European sites (AONB unit, Natural England, Council records)
  • Cultural heritage
  • Landscape
  • Biodiversity
  • Flora
  • Fauna
  • Water

Cultural Heritage

14. To conserve and where appropriate enhance areas and assets of historical and archaeological importance (13)

  • Will it protect and enhance buildings, monuments, sites, places, areas and landscapes of heritage interest or cultural value (including their setting) meriting consideration in planning decisions?
  • Will it protect and enhance sites, features and areas or archaeological value in both urban and rural areas?
  • Will it enhance accessibility to and the enjoyments of cultural heritage assets?
  • Change in the number of designated and non-designated heritage assets (English Heritage, Council records)
  • Number of heritage assets recorded as 'at risk' (English Heritage, Council records)
  • Cultural heritage


15. To conserve and enhance the quality and local distinctiveness of landscapes and townscapes (14)

  • Will it conserve and enhance the AONB?
  • Will it reduce the amount of derelict, degraded and underused land?
  • Will it protect and enhance the settlement and its setting within the landscape?
  • Will it protect and enhance landscape character and townscapes? 
  • Will it promote high quality design in context with its urban and rural landscape?
  • Development brought forward through regeneration projects (Council records)
  • Development granted in AONB or Special Landscape Area designations. (Council records)
  • Air
  • Material assets
  • Water
  • Cultural heritage
  • Population
  • Biodiversity
  • Climate factors


16. To achieve sustainable levels of prosperity and growth throughout the plan area (15)

17. To maintain and enhance the vitality and viability of town and retail centres (16)

  • Will it improve business development and enhance competitiveness?
  • Will it improve the resilience of business and the economy?
  • Will it promote growth in key sectors?
  • Will it improve economic performance in disadvantaged areas?
  • Will it encourage rural diversification?
  • Will it encourage indigenous business?
  • Will it encourage inward investment?
  • Will it make land available for business development?
  • Will it increase the range of employment opportunities, shops and services available in town centres?
  • Will it decrease the number of vacant units in town centres?
  • Will it enhance the local distinctiveness within the centre?
  • Estimated new job creation (Council records)
  • Net additional gains in employment land development (Council records)
  • Business formation rate (Suffolk Observatory)
  • Number of business paying business rates (Council records)
  • Numbers employed by industry (Oxford Economics - East of England Forecast Model)
  • % of A1 use class and vacant units in town centres (Council records)
  • Population
  • Human health
  • Material assets

Transport, Travel and Access

18. To encourage efficient patterns of movement, promote sustainable travel of transport and ensure good access to services. (17)

  • Will it reduce commuting?
  • Will it improve accessibility to work by public transport, walking and cycling?
  • Would it promote the use of sustainable travel modes and reduce dependence on the private car?
  • Will it increase the proportion of freight transported by rail or other sustainable modes?
  • Will it maintain and improve access to key services and facilities for all sectors of the population?
  • Will it increase access to the open countryside?
  • Will it increase access to public open space?
  • Will it improve access to cultural facilities?
  • Will it improve access to community facilities?
  • Will it reduce journey times?
  • Will it help to enhance the connectivity of more remote, rural settlements?
  • Loss of key services (council records)
  • Provision of key infrastructure projects (IDP, Council records)
  • Travel to work distances (Census)
  • Travel to work modes (Census)
  • Material assets
  • Climate factors
  • Landscape
  • Population

Digital Infrastructure

19. To ensure that the digital infrastructure available meets the needs of current and future generations

  • Will it improve digital infrastructure provision?
  • Will it increase opportunities to improve the digital economy?
  • Average Broadband speeds (County records)
  • Population
  • Material assets

How will the SA be undertaken?

The SA will appraise the following key parts of the Local Plan (and reasonable alternatives where these exist):

  • Vision and Objectives – compatibility matrix – Chapter 7
  • Spatial Strategy – appraisal matrix – Appendix II
  • Plan Policies – Appendix II
  • Site Allocations – Appendix II

What are the Next Steps in the SA Process?

The draft Scoping Report will be subject to a ten-week period of public consultation between 18th August and 30th October. 

In accordance with the national regulations and the Council's Statement of Community Involvement, the public consultation will have a specific focus on statutory agencies such as Historic England, Environment Agency and Natural England.  Input and consultation responses from other statutory and non-statutory stakeholders such as RSPB, Suffolk Wildlife Trust and neighbouring Local Authorities will also be invited.

In responding to this scoping report, we would appreciate a response to the following questions:

SA Q1. Have we captured the right information in our review of plans and programmes and production of baseline evidence and analysis?

  1. Have we missed any areas?
  2. Where is information on this/these topics available from?

SA Q2. Are the economic, social and environmental issues we have identified in this report relevant to the SA of the Ipswich Local Plan?

  1. Are there any issues you think we need to include?
  2. Are there any issues you think we need to exclude?

SA Q3. Do you agree with the proposed approach to the SA of the Local Plan?

  1. Do the SA objectives and guide questions that comprise the SA Framework cover a sufficient range of environmental, social and economic topics?
  2. Are there any objectives/guide questions which should be amended?
  3. Are there any other objectives/guide questions which we should include?

Any comments received during the consultation period will be taken into account and where relevant the Scoping Report will be revised and republished to reflect the representations ahead.

Should you have any comments on the Scoping Report, please email any comments or information you may have to planningpolicy@ipswich.gov.uk or alternatively post them to the following address:

Planning Policy

Planning and Development

Ipswich Borough Council

Grafton House

15-17 Russell Road



[2] Figures in brackets show the equivalent Babergh Mid Suffolk DC objective

[3] Highlighted text shows areas of difference between SCDC/IBC framework and BMSDC framework.

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