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

5. Appraisals of Strategic Options

   1. Housing Needs and Employment Trends
      1. In 2017, the Council consulted on the Issues and Options documents. At that time, Ipswich was considered to have an Objectively Assessed Need (OAN) of 11,420 dwellings over the LPR period of 2014 – 2036.
      2. In July 2018, the Government published the revised National Planning Policy Framework, which requires local planning authorities to use a standard method to quantify local housing need. Using the standard method and the most up to date 2016-based household projections and affordability information at October 2018 as a starting point, the figure for Ipswich Borough is 479 dwellings per annum 2018 to 2036, or 8,622 dwellings for the eighteen-year period. On 26th October 2018, the Government issued a consultation proposing that local planning authorities use the 2014-based household projections rather than the 2016-based projections in their housing need assessments. The effect of this would be to reduce the figure, but until the guidance has been finalised, the higher figure will be planned for. This figure will be reviewed at the next stage of plan preparation.
      3. Three key evidence bases informed the employment needs identified for the Ipswich FEA:

• Jobs calculations from the East of England Forecasting Model (EEFM) (August 2016);
• Employment Sector Needs Assessment (ESNA) (2017); and
• Employment Land Supply Assessment (ELSA) (2017).
  4. The EEFM identified a likely increase in the number of jobs needed in Ipswich from 75,195 in 2014 to 94,235 by 2036. The Council are therefore seeking to deliver approximately 15,580 jobs for the 2018 – 2036 period.
  5. Each scenario of different quantities of growth has been assessed for its likely impacts on each SA Objective in Appendix C. The scores recorded for each strategic option against each SA Objective are presented in Table 5-1 as an indicator of the likely overall sustainability impacts.

2. Growth scenarios
   1. The Issues and Options consultation identified three potential scenarios for delivering the required level of housing and economic growth in Ipswich by 2036, as well as tackling other challenges the Borough faces. The Council's intention is to pursue the growth option of delivering 479 dpa, and this approach will be reviewed at the next stage of the Plan-making process.
   2. In accordance with the SEA Directive, which requires reasonable alternatives to be appraised for their likely significant effects, the likely impacts of each growth scenario are appraised in Appendix C. An additional growth scenario was been appraised based on the new OAN figure. In sum, the following growth scenarios have been appraised:

• Preferred approach (Policy CS7(homes) and Policy CS13 (jobs)): 8,622 homes and 15,580 jobs - A trend-based scenario based on the forecast employment needs of the Borough and the 2018 update to the OAN based on the standardised method;
• Alternative Scenario A: 11,420 homes and 19,040 jobs - A trend-based scenario based on the forecast employment needs of the Borough and the 2017 calculated OAN;
• Alternative Scenario B: 25,837 dwellings and 32,376 jobs – A policy-led scenario for significant economic growth, with a 20% increase in the 2017-homes target relative to OAN; and
• Alternative Scenario C: 30,143 dwellings and 32,376 jobs - An infrastructure-led scenario based on a high increase in growth in Ipswich, with a 40% increase in the 2017-homes target relative to OAN.
  3. The nature of the appraisal process involves a degree of uncertainty that requires the use of professional judgement. The appraisals are based on the identified evidence base. Residential development is assumed to be in-perpetuity, and so the likely impacts of development on society, the natural environment or the local economy are also likely to reside in perpetuity should mitigation not be employed.

3. Spatial options
   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, the likely social, environmental and economic impacts of each are presented in Appendix C (Spatial Options 4, 5 and 6 relate to the administrative boundary of Suffolk Coastal District only):

• 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;

Options from Suffolk Coastal District Council

• Spatial Option 4: Continuation of existing approach (Suffolk Coastal District);
• Spatial Option 5: Focus on Ipswich and A14 transport corridor (Suffolk Coastal District); and
• Spatial Option 6: A12 transport corridor and dispersed rural focus (Suffolk Coastal District).
  2. The appraisal of spatial options inherently involves a degree of uncertainty and assumptions are required throughout. By their nature, these assessments account for the cumulative and synergistic effects of development in combination and the identified impacts can be expected to arise in the short term and reside for the long term. Residential development is assumed to be in perpetuity, and so in the absence of mitigation any impacts on the local community, natural environment or economy can also be assumed to be in perpetuity i.e. new homes would be likely to remain for hundreds of years and, should these new homes result in the loss of soils or woodland it is likely that this loss will also remain for a similar duration.

4. Summary of assessments: Growth
   1. The appraisal of growth scenarios and spatial options in Appendix C identified a range of potential positive and adverse effects, with often mixed results identified against most SA Objectives. These effects are generally related to the fact that Ipswich is a highly constrained and urban Borough that can only support a limited amount of new development. The Preferred Approach (i.e. Policy CS7 in the LPR) and Alternative Scenario A would lead to nearly all new development occurring within the Borough, whereas under Alternative Scenarios B and C the quantity of development being considered would be likely to necessitate a significant quantity of development outside of the Borough in neighbouring authorities, most likely on greenfield sites.
   2. 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 environmental objectives such as biodiversity, cultural heritage and landscape. This is 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 and synergistic effects on the ecological network or the local landscape character, for example. As such, Preferred Approach and Alternative Scenario A could potentially result in less adverse effects on biodiversity and landscape than Alternative Scenarios B and C.
   3. Furthermore, the Preferred Approach and Alternative Scenario A may help to limit adverse impacts on natural resources, waste and climate change objectives. The lower quantities of development would facilitate a higher proportion of development to be situated on brownfield sites in urban locations than Scenarios B and C and would therefore be likely lead to less severe losses of agriculturally and ecologically valuable soils. Access to sustainable transport modes, and distances to key services and amenities, typically enable more sustainable lifestyles with lower carbon footprints. The Preferred Approach and Alternative Scenario A could therefore be expected to have less severe impacts on climate change mitigation and air quality than Scenarios B and C. It is also expected that the lower quantities of development in the Preferred Approach and Scenario A would lead to a much more limited rise in water consumption and waste generation.
   4. The costs or benefits of each growth scenario on access to health and education facilities is complex. The Proposed Approach and Alternative Scenario A would help to situate new residents in proximity to existing services. However, there are existing capacity concerns at Ipswich's schools and some doctor's surgeries and, without the provision of new services, the Preferred Approach or Scenario A could exacerbate capacity concerns. In contrast, Alternative Scenarios B and C could situate new residents in locations that are isolated from existing services, largely depending on the precise location of new sites in relation to settlements in neighbouring authorities. However, the larger scale of growth under these options would be likely to facilitate the provision of new services and facilities, some of which would be on-site, and Scenarios B and C may therefore help lead to an increased capacity.
   5. A large portion of land in the centre of Ipswich is situated in Flood Zones 2 or 3. It is considered to be likely that all growth scenarios would utilise all the available land for development within Ipswich, and therefore under all scenarios it will be difficult to situate new development on land not at risk of flooding in all cases.
   6. It has so far been identified that the Preferred Approach and Alternative Scenario A would be likely to have more beneficial impacts on SA Objectives related to biodiversity, landscape, climate change, waste, natural resources, cultural heritage, social exclusion and air quality.
   7. However, Alternative Scenarios B and C offer some advantages. Crucially, there is a risk that focussing development in urban locations would lead 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. Careful consideration should be given to the protecting the quality of life and long-term health for these residents. It is likely that Scenarios B and C would enable a large portion of new residents to pursue healthy and active lifestyles.
   8. 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 than would perhaps be seen under the Preferred Approach or Alternative Scenario A. Scenario C would go further than Scenario B and deliver significant infrastructure projects that could lead to a range of economic and social benefits.
5. Summary of assessments: Spatial
   1. The appraisal of spatial scenarios in Appendix C identified a range of benefits and likely impacts of each scenario. It is anticipated that certain spatial scenarios would help to facilitate different quantities of growth. The Preferred Approach and Alternative Scenario A would see nearly all new development occur in the Borough. Spatial Option 1: Higher-density urban regeneration and Spatial Option 3: Changing the use of existing land in the Borough to housing would help to deliver these growth options. In contrast, Alternative Scenarios B and C would require a large quantity of development to occur outside the Borough and in order to do so a combination or spatial scenarios would be required.
   2. Spatial Option 1 would focus development in urban locations where access to services, amenities and sustainable transport modes is very good. Impacts on the natural environment, such as biodiversity, may be much less likely under this option than others. However, it would require a high density of development that in some locations could potentially reduce the quality of living for residents