Strategic Environmental Assessment and Sustainability Appraisal (includes Non-Technical Summary)

Ended on the 13 March 2019

Non-Technical Summary

Introduction and Background

  1. In February 2017, Ipswich Borough Council (the Council) adopted the Local Plan 2011 – 2031. The Council is now preparing a review of the Local Plan, which will replace the Adopted Plan and will look ahead to 2036. The process commenced with consultation on the Issues and Options between August and October 2017, which was accompanied by a Sustainability Appraisal (SA) Scoping Report. The Council has now prepared their Preferred Options version of the Local Plan Review (LPR). The LPR Preferred Options is presented in two documents:
  • Core Strategy and Policies DPD Review Preferred Options; and
  • Site Allocations and Policies (incorporating IP-One AAP) DPD Preferred Options.
  1. The Core Strategy document presents the Council's preferred approach for a Vision and Objectives for the Borough by 2036. It also proposes policies related to the Council's strategy for the Borough. The Site Allocations and Policies document presents a range of site-based policies. This report is an Interim SA Report that provides an appraisal of the likely sustainability impacts of the LPR, to accompany the Preferred Options Consultation.

What is a Sustainability Appraisal?

  1. A SA is a process for assessing the social, economic and environmental impacts of a plan and it aims to ensure that sustainable development is at the heart of the plan-making process. It is a legal requirement under planning law[1]. The law states that the SA must also comply with requirements of the European Strategic Environmental Assessment (SEA) Directive. For the purpose of readability, this report, which is an Interim SA/SEA Report, is referred to as the Interim SA Report.
  2. Good practice guidance proposes a number of prescribed stages in the SA process, each of which links with stages of the plan-making process. It is important that the SA feeds into the plan-making process to assist the Council with their decision-making process on how best to prepare the LPR, who will also be considering other evidence documents alongside the SA. This involves the ongoing appraisal of the LPR and making recommendations to help steer its direction to avoid potentially adverse consequences. This is particularly important when considering alternative strategy options. Consultation with statutory bodies (Natural England, Historic England and Environment Agency) and the public is also required at key stages.

Scope of the Appraisal

  1. The first part of a SA is the Scoping Report which:
  • Reviews other relevant programmes, plans and strategies that have an influence on sustainability;
  • Details the characteristics of the current environmental baseline in Ipswich;
  • Identifies key sustainability issues in the Borough; and
  • Sets out a Sustainability Appraisal Framework for assessing policy options and the overall effect of the plan (Task A4).
  1. The Scoping Report was prepared in March 2017 by the Council. It was then consulted on between 18th August and 30th October 2017 with, as a minimum, the three statutory consultees of Natural England, the Environment Agency and Historic England. The Scoping Report was finalised for February 2018 in light of responses received during the consultation window.

Policy context

  1. A comprehensive review of other plans and programmes at a national, regional, county and local level was undertaken. The contents, objectives and relationships of these plans and programmes to the LPR was also reviewed to ensure these are taken into account during the SA Process. An example of a relevant plan/programme includes the National Planning Policy Framework. The full list of the identified plans and programmes, and their relevance to SA, is provided in Appendix A of this report as well as in the February 2018 SA Scoping Report.

Characteristics of Ipswich and key sustainability issues and opportunities

  1. Among the important decisions considered during the Scoping Report was the baseline data, quantity of data and how should it be used in order to carry out SA. Data related to the existing economic, social and environmental characteristics of Ipswich was compiled within the Scoping Report, in order to provide the evidence base from which sustainability issues and opportunities could be identified. The key sustainability issues and opportunities that were subsequently identified related to the themes of: Population, Housing, Health and Wellbeing, Education, Water, Air, Material Assets, Climatic Change, Flooding, Coasts and Estuaries, Biodiversity, Cultural Heritage, Landscape, Economy, Transport & Connectivity and Digital Infrastructure. The baseline data and key sustainability issues are presented in the SA Scoping Report (February 2018).

The SA Framework

  1. The SA Framework comprises 19 SA Objectives that have been derived from the policy context, baseline data and key sustainability issues and opportunities. Each proposal in the LPR is assessed for its likely impacts on each SA Objective, which is largely achieved by using the Guide Questions listed in the SA Framework for each SA Objective. The SA Framework, which is presented in its entirety in the main body of this report, as well as within the February 2018 Scoping Report, includes the following SA Objectives:
  1. To reduce poverty and social exclusion;
  2. To meet the housing requirements of the whole community;
  3. To improve the health of the population overall and reduce health inequalities;
  4. To improve the quality of where people live and work;
  5. To improve levels of education and skills in the population overall;
  6. To conserve and enhance water quality and resources;
  7. To maintain and where possible improve air quality;
  8. To conserve and enhance soil and mineral resources;
  9. To promote the sustainable management of waste;
  10. To reduce emissions of greenhouse gases from energy consumption;
  11. To reduce vulnerability to climatic events and flooding;
  12. To safeguard the integrity of the coast and estuaries;
  13. To conserve and enhance biodiversity and geodiversity;
  14. To conserve and where appropriate enhance areas and assets of historical and archaeological importance;
  15. To conserve and enhance the quality and local distinctiveness of landscapes and townscapes;
  16. To achieve sustainable levels of prosperity and growth throughout the plan area;
  17. To maintain and enhance the vitality and viability of town and retail centres;
  18. To encourage efficient patterns of movement, promote sustainable travel of transport and ensure good access to services; and
  19. To ensure that the digital infrastructure available meets the needs of current and future generations.

What has been assessed in the SA?

  1. Essentially, every proposal in the LPR has been assessed for its compatibility with, or likely impacts on, each SA Objective. The proposals in the LPR include the following:
  • A Vision for Ipswich;
  • Objectives, the achievement of which would deliver the vision;
  • Strategic options, including the amount of development that should take place in Ipswich (including residential development and economic development) as well as the spatial strategy that should be employed to deliver this amount of development;
  • Core Strategy Policies;
  • Development Management Policies; and
  • Site policies (including policies that determine the specific types and quantities of development that should take place at specific locations in the Borough).
  1. In order to satisfy the requirements of the SEA Directive and the SEA Regulations, as well as to be legally compliant in light of relevant case law, the Council have had to consider reasonable alternatives to each of the proposals in the LPR. Each of the reasonable alternatives considered by the Council has also been considered for its likely sustainability impacts using the SA Framework.
  2. When identifying and describing effects in SEA, the following effect characteristics are accounted for:
  • Whether the effects are positive or negative;
  • The magnitude and spatial extent of effects;
  • The probability, duration, frequency and duration of effectives;
  • The cumulative nature of effects;
  • The transboundary nature of effects; and
  • The value and vulnerability of that which is being affected.
  1. Based on the assessment results, this Interim SA Report also provides recommendations for either enhancing a proposal's positive impacts, or measures for avoiding or reducing likely adverse effects.

Appraisal results

Vision and Objectives

  1. The Core Strategy Review document presents a Vision for the Borough by 2036. It also sets out twelve Strategic Objectives in order to realise this Vision. The Vision and Strategic Objectives were assessed for their compatibility with the SA Framework. On the whole, the Council's Vision and Strategic Objectives proposed for the LPR were found to be highly compatible with the SA Framework and would be expected to help ensure the LPR delivers socially, economically and environmentally sustainable land-uses and development until 2036.

Strategic Options

Quantity of growth

  1. The SA provides an appraisal of the likely sustainability impacts of different options for the amount of development that should take place in Ipswich, including:
  • Preferred Approach (Policy CS7 (homes) and Policy CS13 (jobs)): 8,622 homes and 15,580 jobs;
  • Alternative Scenario A: 11,420 homes and 19,040 jobs;
  • Alternative Scenario B: 25,837 dwellings and 32,376 jobs; and
  • Alternative Scenario C: 30,143 dwellings and 32,376 jobs.
  1. The Preferred Approach, which proposes the provision of 8,622 homes and 15,580 jobs, is the scenario pursued in the Preferred Options LPR through Policies CS7 and CS13.
  2. The results of these assessments are presented in their entirety in the appendices of this Interim SA Report.
  3. Generally speaking, it was considered that the lower the quantity of development being considered, the more feasible it would be to avoid adverse impacts on biodiversity, landscape, climate change, waste, natural resources, cultural heritage, social exclusion and air quality. This is mostly because fewer sites would be required for development and there would, therefore, be less scope for direct harm to sensitive assets as well as more limited cumulative effects on the ecological network or the local landscape character, for example. Avoiding adverse impacts on natural environment objectives, and achieving positive impacts, may therefore be more feasible under the Preferred Approach or Alternative Scenario B than it would be under Alternative Scenarios B and C.
  4. However, Alternative Scenarios B and C offer some advantages. Alternative Scenarios B and C would facilitate an economic transformation in the Borough. They would be likely to help significantly tackle rates of deprivation and contribute towards a more prosperous and sustainable local economy as well as make a greater contribution towards vital and vibrant town centres. Alternative Scenario C would go further than Alternative Scenario B and deliver significant infrastructure projects that could lead to a range of economic and social benefits. However, this additional economic growth under Alternative Scenarios B and C would be highly likely to result in major adverse natural environmental impacts.

Spatial distributions

  1. In order to deliver development through the LPR, the Council is considering a range of different spatial distribution options. Given the tightly drawn boundary around the Borough, the range of spatial options available to the Council is limited. Six different options for delivering the desired growth have been identified:
  • Spatial Option 1: Higher-density urban regeneration;
  • Spatial Option 2: Increased development beyond the Borough boundary;
  • Spatial Option 3: Changing the use of existing land in the Borough to housing;

Spatial Options 4, 5 and 6 were options that applied to the administrative area of Suffolk Coastal District Council. These are as follows:

  • Spatial Option 4: Continuation of existing approach;
  • Spatial Option 5: Focus on Ipswich and A14 transport corridor; and
  • Spatial Option 6: A12 transport corridor and dispersed rural focus.
  1. The results of these assessments are presented in their entirety in the appendices of this report.
  2. Higher density urban regeneration poses a risk of leading to a large portion of new residents being exposed to major sources of noise, air and light pollution such as that associated with road traffic. Higher density developments can also reduce the quality of the living environment. At the same time, it is an effective means of making an efficient use of land, situating residents in proximity to jobs, services, facilities and public transport modes as well as avoiding adverse impacts on sensitive natural landscapes or important wildlife areas.
  3. Options of situating a large portion of development outside the Borough or within the corridor of main roads has the opposite effect. It would situate residents in proximity to the countryside and within lower density developments, away from areas of high pollution. However, adverse impacts on the natural environment are more difficult to avoid in these locations whilst residents would have to travel longer distances to access jobs, services and facilities and would be likely to have a relatively high reliance on personal car usage for doing so given the more limited access to public transport modes here.

Core Strategy Policies

  1. The Core Strategy LPR document presents a range of Core Strategy Policies related to: the Spatial Approach, Live, Work, Learn, Play and Infrastructure. Each of these has been assessed in detail in the appendices of this report. The results of the assessments of core strategy policies identified largely positive impacts for all SA Objectives. Where opportunities were identified for enhancing positive or adverse effects, or avoiding or minimising adverse effects, recommendations were made.

Development Management Policies

  1. The Core Strategy LPR Document also presents policies in order to enable the Council to manage development in the Borough and ensure it is sustainable. Where development proposals do not accord with these policies, they are less likely to be granted permission by the Council. Each of these has been assessed in detail in the appendices of this report. The results of the assessments of development management policies identified largely positive impacts for all SA Objectives. Where opportunities were identified for enhancing positive or adverse effects, or avoiding or minimising adverse effects, recommendations for achieving this were made.

Site Policies

  1. The Site Allocations and Policies LPR Document presents 15 site policies, within which various sites in the Borough are allocated for certain types and quantities of development. Each site allocation has been assessed in detail for its likely sustainability performance, the full results of which are presented in their entirety in the appendices of this report. Overall, a highly diverse mix of likely impacts were identified. Where opportunities were identified for enhancing positive or adverse effects, or avoiding or minimising adverse effects, recommendations for achieving this were made.

Cumulative effects

Cumulative effects of all proposals in the LPR

  1. The policies and site allocations proposed in the LPR were assessed on an individual basis, in detail, in the appendices of this report. However, these sites and policies would not be adopted in isolation. The effects of policies and sites would combine to result in cumulative effects across the Borough. An assessment of the likely cumulative effects of sites and policies in combination was also carried out in this report.
  2. Major positive cumulative effects of all proposals in the LPR in combination with each other were identified for SA Objectives: to reduce poverty and social exclusion; to meet the housing requirements of the whole community; to improve levels of education and skills in the population overall; to achieve sustainable levels of prosperity and growth throughout the plan area; to encourage efficient patterns of movement, promote sustainable travel of transport and ensure good access to services; and to ensure that the digital infrastructure available meets the needs of current and future generations.
  3. Minor adverse cumulative effects of all proposals in the LPR in combination with each other were identified for SA Objectives: to improve the quality of where people live and work; to conserve and enhance water quality and resources; to maintain and where possible improve air quality; to conserve and enhance soil and mineral resources; to promote the sustainable management of waste; to reduce emissions of greenhouse gases from energy consumption; to reduce vulnerability to climatic events and flooding; and to conserve and enhance the quality and local distinctiveness of landscapes and townscape.

Cumulative effects of proposals in the LPR with development in neighbouring authorities

  1. Following the assessment of cumulative effects caused by all LPR proposals in combination, an assessment of the cumulative effects of proposals in the LPR in combination with development planned in neighbouring authorities was also carried out.
  2. Major positive cumulative effects of all proposals in the LPR in combination with development plans in neighbouring authorities were identified for SA Objectives: to meet the housing requirements of the whole community; to achieve sustainable levels of prosperity and growth throughout the plan area; and to maintain and enhance the vitality and viability of town and retail centres.
  3. Minor adverse cumulative effects of all proposals in the LPR in combination with development plans in neighbouring authorities were identified for SA Objectives: to improve the quality of where people live and work; to improve levels of education and skills in the population overall; to conserve and enhance water quality and resources; to maintain and where possible improve air quality; to conserve and enhance soil and mineral resources; to promote the sustainable management of waste; to reduce emissions of greenhouse gases from energy consumption; to reduce vulnerability to climatic events and flooding; to conserve and enhance biodiversity and geodiversity; and to conserve and enhance the quality and local distinctiveness of landscapes and townscape.
  4. It is important to note that likely effects are complex, and effects summarised as 'positive' or 'adverse' often involve a mixture of both positive and adverse effects. SA adopts a precautionary approach that dictates that, where there is uncertainty of an overall effect, adverse effects should be highlighted.

Mitigation

  1. The assessment of proposals in the Ipswich LPR has identified the likely significant effects, including those that are positive and adverse. Where adverse effects were identified, recommendations have been made to help avoid or minimise these effects. Where positive effects have been identified, recommendations have been made to enhance these effects where feasible. Recommendations are included within the policy and sites assessments in the appendices of this report.
  2. The most frequent measure recommended throughout the assessments has been the development of a coherent, high-quality and connected GI network extending throughout and beyond the Borough. This network could include all forms of GI such as parks, hedgerow and mature trees. The GI network should be designed and managed in a way that:
  • Helps to ensure it is of high biodiversity value, provides refuge for protected habitats and priority species and enables the free movement of wildlife through and beyond the Borough;
  • Makes a positive contribution to the local townscape and landscape character, including by being visually attractive, in-keeping with the existing setting, helping to screen development and protect views and by linking development sites with the natural landscape;
  • Contributes towards visually attractive regenerations of derelict brownfield sites;
  • Helps to protect and enhance the structure and fertility of soils;
  • Contributes to the sustainable management of surface water runoff, thereby helping to manage flood risk and protect water quality;
  • Helps to filter out air pollutants and contribute towards cleaner air, as well as to act as a carbon capture and storage service;
  • Provides residents with access to greenspaces and a diverse range of natural habitats, as well as safe and attractive pedestrian and cycle routes to services, facilities and amenities, in order to benefit their mental well-being, to encourage physical activity and to facilitate sustainable and efficient forms of movement;
  • Facilitates community engagement and outdoor socialisation to reduce the risk of social exclusion; and
  • Provides good links in to central and shopping areas to increase the footfall here and support local businesses.

Monitoring

  1. This Interim SA Report also proposes a Draft Monitoring Framework. The Draft Monitoring Framework is proposed to measure the performance of the LPR, including the Core Strategy DPD and the Site Allocations DPD, against defined indicators. Indicators in the Monitoring Framework have been developed based on:
  • The objectives, targets and indicators that were developed for the SA Framework;
  • Features of the baseline that will indicate the effects of the plan;
  • The likely significant effects that were identified during the assessment; and
  • The mitigation measures that were proposed to offset or reduce significant adverse effects.
  1. Feedback from the monitoring process helps to provide more relevant information that can be used to pinpoint specific performance issues and significant effects, and ultimately lead to more informed decision-making. In addition to monitoring the sustainability impacts of the LPR, it will also be necessary to monitor changes to the environmental, social and economic context and baseline conditions.
  2. Monitoring in accordance with the SEA Directive can be incorporated into existing monitoring arrangements. The Council prepare an annual Authority Monitoring Report (AMR) to review progress on local development document preparation and monitor the outputs and implementation of current policies. It is expected that the proposed Draft Monitoring Framework in this chapter would be incorporated into the AMR.
  3. The Draft Monitoring Framework proposes monitoring recommendations for predicted significant effects based on the assessment of the Local Plan Review. The framework will be developed further in the next stage of the SA Report, following feedback from consultees, and further refinement of the assessment of significant effects to be monitored.
[1] SA is required by Section 19 of the Planning and Compulsory Purchase Act 2004 http://www.legislation.gov.uk/ukpga/2004/5/section/19. It also incorporates the requirements of European Directive 2001/42/EC
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