ipswich.gov.uk

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

Ended on the 13 March 2019
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  1. Cumulative, Synergistic and Secondary Effects

    1. Background
      1. Annex 1(f) of the SEA Directive requires SEA to provide information on the likely significant effects, including "secondary, cumulative, synergistic, short, medium and long-term permanent and temporary, positive and negative effects".
      2. The assessment of each option indicates whether identified effects are considered to be positive or negative, short, medium or long term as well as permanent or temporary. These assessments of options, presented in the appendices of this report, also account for both direct and secondary effects. The purpose of this chapter is to provide an overview of the likely cumulative and synergistic effects, which can be defined as follows:
  • Cumulative effects arise, for instance, where several proposals each have insignificant effects but together have a significant effect, or where several individual effects of the proposal have a combined effect; and
  • Synergistic effects interact to produce a total effect greater than the sum of the individual effects, so that the nature of the final impact is different to the nature of the individual impacts.

8.2 Cumulative and synergistic effects of proposals in the Ipswich LPR

8.2.1 The Ipswich LPR proposes a range of sites for different types of development across the Borough, in addition to various strategy, development management and site-based policies. Each has been assessed for its likely impacts on each SA Objective in detail. The purpose of this section is to provide an assessment of the likely cumulative effects of all proposals in combination against each SA Objective. This process naturally involves a large degree of uncertainty and assumptions have to be made in each case. Best efforts have been made to provide an indication of the overall uncertainty of effects and to identify likely significant effects. The results of this process as presented in Table 8-1.


Table 8-1: Cumulative and synergistic effects assessment of proposals in the LPR

Key:

++

Major positive effect (significant)

+

Minor positive effect

0

Neutral effect

?

Uncertain effect

-

Minor adverse effect

--

Major adverse effect (significant)

SA Objective

Overall score

Duration & uncertainty

Commentary

1 - To reduce poverty and social exclusion

++

S-LT

Low uncertainty, Reversible

Likely significant effects:

The LPR allocates a range of residential sites in locations that will help to ensure the significant majority of Ipswich's residents have excellent access to community facilities and areas, such as open spaces, arts and cultural facilities as well as those associated with the night-time economy. Various policies safeguard and seek to enhance community facilities, particularly those in locations accessible via public transport modes and walking and cycling. Cumulatively and synergistically, the LPR would therefore make a major contribution towards combatting the risk of social exclusion. The provision and enhancement of digital infrastructure, including that which can adapt to future technologies like 5G, will also help to combat risk of social exclusion.

The LPR allocates a range of employment sites, the combination of which would facilitate the anticipated growth in jobs and prosperity in the Borough. It is highly likely that the growth in local employment opportunities for residents will make a major contribution towards tackling poverty, through increased employment.

The significant majority of new homes would have excellent access to education facilities whilst there will, in some cases, be the provision of expanded or new education facilities. Educational attainment can be a highly effective route out of poverty.

Recommendations:

New or enhanced community facilities should be designed and managed in a manner that encourages as much community interaction as possible, with support provided that encourages community engagement for all of the local population's diverse preferences. Particular efforts may be needed for categories of society more prone to loneliness, including those aged 16 – 24.

2 - To meet the housing requirements of the whole community

++

S-LT

Low uncertainty, Reversible

Likely significant effects:

The Council have identified the OAN for the Borough based on the best available data using the most up to date methodology. The LPR has allocated enough land to accommodate new homes to the extent that the OAN can be satisfied over the LPR period with a five-year supply consistently identified.

Of these new homes, the Council has determined that, based on trend data and the SHMA, there is a need for 19.5% of housing to be Affordable Rented and 14.8% affordable home ownership. The Council have therefore determined that, for sites of 10+ dwellings, there should be provision of at least 15% on-site affordable housing by number of dwellings, 60% of which should consist of affordable housing for rent.

Cumulatively and synergistically, the LPR would make a major contribution towards meeting the housing requirements of the whole community.

Recommendations:

Homelessness rates have been declining in Ipswich over the past few years. The provision of affordable homes over this period has no doubt contributed towards this. It is recommended that developments are strongly encouraged to exceed the 14.8% rate where feasible.

3 - To improve the health of the population overall and reduce health inequalities

+

S-LT

Medium uncertainty, Reversible

Likely significant effects:

The proposed residential sites allocated for development in Ipswich would be expected to situate nearly all new residents in locations where they are within 1-4km, and typically within 1km, of a GP surgery as well as within 8km of Hospitals. A new doctor's surgery is included within the IP005 site allocation in the north west of the Borough, where access to a GP surgery is currently somewhat limited.

For some residents, access to a diverse range of natural habitats is limited given their relatively urban location in central Ipswich. However, access to open spaces including public parks is generally very good, particularly as a number of sites include the provision of open space (as allocated in Policy SP6).

It should also be noted that approximately 5.8% of mortality in Ipswich is considered to be associated with Nitrogen Oxide (NOx) pollution, higher than the 5.3% average seen for England. This is due to the relatively poor air quality in several areas of the Borough. Many sites proposed for residential development in the LPR are adjacent to A-roads or in proximity to AQMAs, where NOx pollutant is a particular concern. Whilst there are policies in the LPR designed to help improve local air quality, such as Policy DM3 Air Quality, there is a risk that should air quality not improve as much or as fast as hoped, the long-term health of some new residents could be harmed by exposure to particulate pollution.

Recommendations:

There are some concerns over the capacity of GP surgeries across the Borough and careful consideration may be needed to ensure that all new and existing residents are able to access a GP surgery.

Access to a diverse range of natural habitats as well as public open spaces is essential to the physical and mental wellbeing of residents. Best efforts should be made to ensure that all residents are able to walk or cycle to nearby public open spaces as well as natural or semi-natural habitats. Recommendations for sites allocations have been made within the sites assessments, many of which involve incorporating green infrastructure (GI) into the development proposals. Incorporating high quality GI comprised of a diverse range of native species into the development is an effective means of ensuring new residents can experience nature in their daily lives. There should be a strategic overview of this approach to ensure the GI network is designed and laid out in a manner that utilises the air filtering, climate cooling, wildlife supporting, and flood risk alleviating services naturally provided.

4 - To improve the quality of where people live and work

-

S-LT

Medium uncertainty, Reversible

Likely significant effects:

It is expected that in the significant majority of cases, the LPR will help to ensure that people in Ipswich are able to pursue high-quality and active lifestyles both at home and at work. However, given the nature of Ipswich with its network of A-roads and busy roads, as well as the four AQMAs in the centre of Ipswich associated with some of these roads, it is possible that many new residents may be exposed to poor air quality as well as noise and light disturbance associated with road transport and road infrastructure. This air quality will be likely to improve over time in the long-term, given the good access to public transport modes benefitting most of the proposed residential development, as well as their proximity to services, facilities and employment areas (thereby enabling higher rates of walking and cycling) as well as the national trend of moving towards electric and low-emission vehicles.

Various development management policies will be likely to help mitigate this to some extent, including those that would protect and enhance GI and plant cover as well as those that set out requirements for air quality improvement, sustainable construction, low carbon developments and the provision of outdoor amenity spaces. However, overall, a minor adverse impact on the quality of where people live and work as a result of options in the LPR, when considered cumulatively and synergistically, cannot be ruled out.

Recommendations:

Where feasible, new residential development should be situated as far back from sources of noise, air and light pollution as possible. GI should be incorporated into developments as much as possible in a manner that provides an effective means of screening homes from light pollution whilst also filtering out air pollutants. There should be a strategic overview of this approach to ensure the GI network is designed and laid out in a manner that utilises the air filtering, climate cooling, wildlife supporting, and flood risk alleviating services naturally provided.

Where sites are situated in areas of poor air quality, such as within or adjacent to AQMAs, careful consideration would be needed for ventilation in homes and the circulation of fresh air.

5 - To improve levels of education and skills in the population overall

++

S-LT

Medium uncertainty, Reversible

Likely significant effects:

The significant majority of sites allocated for residential development would provide residents with good access to primary and secondary school facilities, frequently being within 500m of a primary school and within 1km of a secondary. Several sites would also provide for an extension to an existing school (e.g. Rosehill) or the provision of a new school (e.g. at site IP048a). This is in line with Policy CS15, which seeks to ensure that there is adequate provision of new or expanded education opportunities to satisfy the needs of the growing local population. The sites assessment results indicate a large portion of new residents may be reliant on schools including St Matthew's Church of England Primary School, St Helen's Nursery and Primary School and Stoke High School and so close consideration on the capacity of these schools may be required.

Local residents also benefit from excellent access to the University of Suffolk as well as Suffolk New College, the continuing development of which the Council also seek to support. The provision of new employment land would also offer the local community with access to a broad range of new jobs, which would be expected to provide opportunities for learning new skills.

Cumulatively and synergistically, options in the LPR would be expected to make a major positive contribution towards improving the levels of education and skills in Ipswich's population overall.

Recommendations:

When determining if there is adequate education provision to satisfy the need, consideration should be given to the accessibility of education opportunities. Residents would ideally be within 500m-1km of their primary school and within 1-2km of their secondary school. Schools should also be accessible via sustainable modes including bus with safe walking and cycling links also provided or enhanced.

6 - To conserve and enhance water quality and resources

-

S-LT

Medium uncertainty, Reversible

Likely significant effects:

In terms of water resources, it is expected that the LPR will ensure there is an adequate supply of water to match the needs of development before it takes place. Given the scale of development proposed in the LPR, it would be expected to result in a net increase in water consumption over the Plan period.

It is considered to be unlikely that water quality would be significantly harmed by the LPR. The majority of sites allocated for development are not within 100m of a natural waterbody and so would not pose a risk to water quality. Some residential and employment sites are adjacent to the River Gipping and the River Orwell and in these cases the construction and operation of development could pose a risk to water quality, although policies in the LPR (as well as EA guidance) will help to minimise this risk. Given the nature of the built form pre-existing in these areas, development here would not pose a major new risk different to that which is already present. Policies such as DM4 and CS1 would help to manage surface water runoff, such as by incorporating SuDS into development, and this will help to reduce the risk of adversely impacting water quality.

Recommendations:

Development adjacent to, or within 100m of, waterbodies and the rivers should incorporate SuDS into the development to reduce the risk of contamination through surface runoff. GI should be incorporated into development in a manner that also helps to reduce rates of runoff. There should be a strategic overview of this approach to ensure the GI network is designed and laid out in a manner that utilises the air filtering, climate cooling, wildlife supporting, and flood risk alleviating services naturally provided. During the construction at these sites, best practice should be adopted to prevent contamination or pollution of nearby waters in line with EA guidance.

7 - To maintain and where possible improve air quality

-

S-LT

Medium uncertainty, Permanent

Likely significant effects:

The LPR proposes the construction and occupation of several thousand new homes as well as the facilitation and operation of thousands of new jobs. It is expected that this would lead to some degree of air pollution, largely due to emissions from buildings and businesses as well as an associated increase in local traffic. It is unclear if this would lead to a net reduction in local air quality, particularly given the below factors and that an air quality study for the Borough found emissions to be improving[4]. However, it is likely that the proposed development in the Borough would make it more difficult to achieve air quality improvement targets, such as at AQMA No. 3 which is within 50m of approximately 800 proposed dwellings.

The LPR proposes various policies that will help to combat air pollution throughout the Borough, particularly DM3: Air Quality which commits the Council to an Air Quality Action Plan that will be published, and which identifies action and measures for reducing emissions. The Council will also require Air Quality Assessments for certain types of development in the Borough. In addition to this, policies which reduce the need for residents to travel, including DM33 on the Delivery and Expansion of Digital Communications Network, and those that enable more sustainable and efficient travel, including DM5 on Improving Accessibility, would help to limit pollution and emissions associated with the transport sector. Policies protecting and enhancing GI and vegetation will help to preserve the air filtering service provided by plants and canopy.

Additionally, the significant majority of development proposed in the LPR would ensure new residents and workers have excellent access to public transport modes including bus and rail. Given their proximity to jobs, homes, services and amenities higher rates of walking and cycling are also likely to be encouraged over time.

It should also be noted that national and international trends, most notably the move towards renewable energies as well as electric and low-emission vehicles, is helping to reduce rates of air pollution from the transport and energy sectors and this will be likely to benefit air quality in Ipswich.

Recommendations:

GI should be incorporated into new developments in manner that filters air pollutants. There should be a strategic overview of this approach to ensure the GI network is designed and laid out in a manner that utilises the air filtering, climate cooling, wildlife supporting, and flood risk alleviating services naturally provided.

Where new residential development occurs, it is likely that they will have good access to a number of bus stops with frequent services. However consideration is likely needed for the capacity of such services and there may in some cases be a need to increase the quantity or frequency of bus services.

Electric vehicle charging points are currently encouraged in new developments. The Council should seek to ensure that these are provided as often as possible.

Residents and employees may be less willing to walk or cycle if their route is deemed unsafe. It is recommended that where pedestrian and cycling links are provided, careful consideration should be given to the safety of these routes, such as by not restricting cycle lanes to narrow strips on busy roads. High quality, attractive and safe routes, that could frequently tie in with the GI network, would encourage good rates of cycling and walking and this may be key to preventing further reductions in air quality.

8 - To conserve and enhance soil and mineral resources

-

S-LT

Low uncertainty, Permanent

Likely significant effects:

The LPR gives close consideration to the potential impacts of its proposals on soils. The significant majority of sites allocated for development are brownfield sites and would constitute an efficient use of land that helps to minimise permanent losses of non-renewable soils. Various policies will be likely to have indirect benefits to soils, including those that seek to protect and enhance biodiversity and above ground biomass given the importance of this for belowground biodiversity and the structure and fertility of soils. The LPR pursues a relatively high density of development in various locations, particularly along the waterfront, and this will help to ensure development uses the Borough's land efficiently.

However, overall, the LPR would be expected to result in a permanent and net loss of ecologically and agriculturally valuable soils, including those that are Grade 2 Agricultural Land Classification (ALC) (i.e. the Borough's best and most versatile soils). This is predominantly due to the 195ha Garden Suburb, nearly all of which is situated on greenfield land and much of which is on Grade 2 ALC land. The provision of 64.5ha of open space and the country park within the Garden Suburb would help to minimise these losses, as too would the range of residential gardens and outdoor amenity spaces. However, a permanent net loss of non-renewable and highly valuable soils would be unavoidable.

Recommendations:

Where development is situated on greenfield land, sustainable soil management techniques should be enforced during the construction phases to avoid the unnecessary losses of soils and to minimise the risk of compaction, contamination or erosion of soils. Where feasible, excavated soils should be reused elsewhere on the site.

9 - To promote the sustainable management of waste

-

S-LT

Medium uncertainty Permanent

Likely significant effects:

The consideration of waste is present in various aspects of the LPR. Several policies, such as CS1 and CS4 will help to ensure that new employment, residential and other forms of development utilise renewable, recycled, reusable and low-impact materials during construction and occupation as well as to ensure that residents and workers have good access to waste recycling facilities. This would make a positive contribution towards limiting the amount of waste sent to landfill. Furthermore, the majority of new development proposed in the Borough is on brownfield and previously developed land. In such cases, there may be opportunities for making good use of pre-existing materials or buildings.

However, overall it is expected that the LPR would result in a net increase in the quantity of waste sent to landfill. This is due to the quantity of development proposed, the increase in the number of workers and residents and the waste that this would generate, not all of which can be or will be recycled or reused.

Recommendations:

It is expected that the majority of waste management in Ipswich would be carried out through Suffolk County Council's Minerals and Waste Local Plan, which was submitted to the Planning Inspectorate on 21 December 2018.

The Council should pursue the ideals of a circular economy as much as feasible, wherein materials are kept in use for as long as possible, as well as to recover and regenerate products and materials at the end of their lives. This may include encouraging developers to make best efforts to reuse any materials, foundations or buildings pre-existing in brownfield or previously developed locations.

10 - To reduce emissions of greenhouse gases from energy consumption

-

S-LT

Medium uncertainty, Permanent

Likely significant effects:

Several components of the LPR will help to limit increases in both energy consumption and GHG emissions in the Borough and it is a key objective of the LPR to reduce the Borough's carbon footprint. In particular, the significant majority of new sites have excellent access to bus, rail, walking and cycling links that will encourage more sustainable and efficient movement that limits GHG emissions associated with road vehicles. Residents of Ipswich typically have a lower carbon footprint per capita than the England average (3.7 tonnes carbon per year for Ipswich vs 6 tonnes carbon per year average for England). GI will be protected in many places throughout the Borough and this will provide a carbon capture and storage service. Policy DM1 sets out strict requirements on new residential development to be relatively energy efficient and for non-residential development to perform well against BREEAM, as well as a requirement for new builds to have carbon emissions 19% below the Target Emission Rate of the 2013 edition of the 2010 Building Regulations.

DM2 sets out standards for decentralised renewable and low carbon energy, with large non-residential developments, and residential developments of 10+ dwellings or 1000m2+, being expected to source at least 15% of their energy from decentralised and renewable or low-carbon sources.

Overall however, the LPR would deliver several thousand new homes and facilitate significant economic growth. This would be expected to lead to some increase in energy consumption, the majority of which would be non-renewable energy. There would also be some degree of increase in local transport movements. Cumulatively and synergistically, the LPR would be expected to contribute towards a net increase in GHG emissions and energy consumption.

Recommendations:

Adapting to and addressing climate change is a particularly urgent challenge for the East of England, which is considered to be highly vulnerable to the impacts of climate change and where a high level of future development is planned, and subsequently high carbon emissions are likely.

It will ultimately be necessary to pursue carbon neutral development. It is recommended that the Council consider opportunities for increasing the emissions reduction standard and energy efficiency homes to the extent that carbon neutral homes are being delivered in Ipswich by 2036.

GI should be incorporated into new developments in manner that filters air pollutants. There should be a strategic overview of this approach to ensure the GI network is designed and laid out in a manner that utilises the air filtering, climate cooling, wildlife supporting, and flood risk alleviating services naturally provided.

11 - To reduce vulnerability to climatic events and flooding

-

S-LT

Low uncertainty, Reversible

Likely significant effects:

Coursing through the centre of Ipswich are the River Orwell and the River Gipping, associated with which are EA Flood Zones 2 and 3. Additionally, throughout the Borough are areas of medium and high surface water flood risk (SWFR). The LPR distributes much of the desired development in locations where flood risk is not a concern. However, this was clearly not feasible for all sites and, particularly for those in the centre of Ipswich, some sites allocated for development are at a high risk of fluvial or surface water flooding.

Some of the policies put forward in the LPR, including DM4 on Development and Flood Risk, will help to minimise the extent of flood risk face by workers and residents at these sites, such as due to the incorporation of SuDS within development proposals. Furthermore, Policy CS18 makes clear that the provision of strategic flood defence infrastructure is a key component of the LPR, delivered through the Ipswich Flood Defence Management Strategy, and integral to ensuring the proposed development can take place.

However, it is expected that the LPR would lead to an increase in the number of residents and employees living and working in Flood Zones 2 and 3, as well as areas of high SWFR. Whilst the proposed mitigation measures and the defence strategy will help to minimise this, it will not be feasible to counter all the risk. It should be noted that the Development and Flood Risk SPD (2016) established that sites in the Borough are safe in terms of flood risk.

Recommendations:

GI should be incorporated into new developments through a strategic approach to ensure the GI network is designed and laid out in a manner that utilises the air filtering, climate cooling, wildlife supporting, and flood risk alleviating services naturally provided.

Where there are areas of high SWFR within site perimeters, development should seek to avoid these through a careful layout. SuDS should also be incorporated into development at these locations to help manage surface water runoff.

12 - To safeguard the integrity of the coast and estuaries

+

S-LT

Medium uncertainty, Reversible

Likely significant effects:

No proposals in the LPR would be expected to impact on the coast and estuaries to a major degree, although protection and enhancement is given to the Stour and Orwell Estuaries SPA through Policy CS4. No proposals in the LPR were expected to result in an adverse impact on the coasts and estuaries and Policy CS4 will help provide assurance of this.

13 - To conserve and enhance biodiversity and geodiversity

-

S-LT

Medium uncertainty, Reversible

Likely significant effects:

The significant majority of sites allocated for development in the LPR will provide an opportunity to enhance the local biodiversity value, primarily due to the provision of GI and new habitats in currently brownfield locations of limited biodiversity value.

However, in some cases, and most notably within the large Garden Suburb, there could be an adverse impact on priority species and habitats due to the presence of agricultural land. The Garden Suburb would be expected to result in the loss of a significant quantity of greenfield, although the planned inclusion of a country park and other green infrastructure elements will help to counter this. In addition, as much of the site is regularly ploughed arable farmland, there is scope to enhance biodiversity through the creation of new landscape and green infrastructure features.as identified in the Ipswich Garden Suburb SPD (2017).

Some sites allocated for development are adjacent to County Wildlife Sites, most commonly the River Gipping wildlife site, and adverse impacts may arise from both the construction and occupation phases of development.

Various policies set out in the LPR would seek to ensure that overall biodiversity in the Borough is protected and enhanced over the Plan period, including CS4 which safeguards biodiversity assets as well as DM8, DM9 and DM10 which protect the natural environment, trees and hedgerow as well as green corridors.

Cumulatively and synergistically, it is considered to be likely that the LPR would have an overall minor adverse impact on local biodiversity.

Recommendations:

GI throughout the Borough should be joined in a coherent network that enables the movement of wildlife through the network and into or out of the Borough freely with minimal blocking off by roads or the built form. Best efforts should be made to ensure that the tree canopy in Ipswich increases over the Plan period, which can only be achieved by ensuring new developments include the provision of new GI that is in part comprised of tree planting. GI should be comprised of a diverse range of native species capable of supporting a diverse range of wildlife, including insects. Blue infrastructure such as wildlife rich ponds and streams should be protected and enhanced within the GI network.

14 - To conserve and where appropriate enhance areas and assets of historical and archaeological importance

+

S-LT

Medium uncertainty, Reversible

Likely significant effects:

Adverse impacts on the historic environment or sensitive heritage assets are considered to be highly unlikely in most cases. This is because the significant majority of sites allocated for development in the Borough are on previously developed brownfield sites, many of which are vacant or derelict plots that are visually unattractive and currently have a negative impact on the local character and setting. Notwithstanding this, these sites may still have archaeological interest which needs to be appropriately assessed, and may be within proximity to Listed Buildings and other heritage assets. As such, development here is an opportunity to improve the site's contribution to the local character and positively enhance the setting of any nearby heritage assets. Additionally, the centre of Ipswich has swathes of archaeological interest relating to a Saxon settlement. Development in these locations will often be a chance to conduct investigation into the presence of known and unknown archaeological assets.

Various policies are also proposed in the LPR to inform the strategy and guide development in a manner that will protect and enhance the historic environment, including CS4 on protecting assets, DM13 on the heritage environment and DM14 on archaeology.

Recommendations:

Given the historic character of Ipswich and the range of Listed Buildings and other assets, much of the proposed development is in proximity to sensitive assets and areas. In each case, efforts should be made to ensure the site makes a positive contribution to the local character and setting through a careful layout, high-quality design, vernacular architecture and the incorporation of GI.

15 - To conserve and enhance the quality and local distinctiveness of landscapes and townscape

-

S-LT

Medium uncertainty, Reversible

Likely significant effects:

As the majority of sites are previously developed brownfields in urban locations, and are frequently vacant or derelict, it is likely that most new development delivered through the LPR will make a positive contribution to the local townscape character. Various strategy and development management policies are also designed to ensure that new development is situate where it is in-keeping with the existing setting and nearby uses. No adverse impacts on an AONB were identified.

However, in a limited number of cases and most notably with the Garden Suburb and potentially the Humber Doucy Broad Location, adverse impacts on character are considered to be likely. This is due to the loss of large greenfield sites and their replacement with the built form, although measures included in the Garden Suburb Supplementary Planning Document, such as the country park and other green infrastructure elements, will help to limit adverse impacts on character. It is expected that DM policies will help to ensure development is of a high-quality design with GI incorporated and this will help to limited adverse impacts.

Recommendations:

High-quality GI comprised of a diverse range of native species, including mature trees, should be incorporated into development that might alter the local character. Best efforts should be made to ensure development is of a design, scale and type appropriate to the area as much as is feasible. In some development proposals, particularly at the Garden Suburb, it may be achievable to adopt innovative mitigation measures that help to screen the built form, such as by focussing the built form in dipped locations, whilst providing attractive GI in more prominent locations.

16 - To achieve sustainable levels of prosperity and growth throughout the plan area

++

S-LT

Low uncertainty, Reversible

Likely significant effects:

The LPR would be expected to make a major positive contribution towards sustainable economic growth and prosperity in Ipswich. This is primary because the quantity of land allocated for employment uses would facilitate the anticipated growth in jobs. Additionally, the distribution of development will help to ensure jobs are highly accessible for residents and businesses are accessible to customers. The provision of new and enhanced digital infrastructure will help to enable local businesses to compete in national and international markets whilst supporting a transition to more internet-based companies.

17 - To maintain and enhance the vitality and viability of town and retail centres

++

S-LT

Low uncertainty, Reversible

Likely significant effects:

Town and retail centres throughout Ipswich would be expected to receive a major boost to their viability and vibrancy over the Plan period due to proposals in the LPR. The support and creation of new jobs would make a direct contribution to their competitiveness. Various DM policies would help to ensure development of particular types and scale are located appropriately to support the competitiveness of centres. The regeneration and rejuvenation of derelict or run-down sites, and various other policies that would enhance the attractiveness and appeal of central areas, will contribute towards and increased footfall in these areas. This is particularly so due to their excellent accessibility via walking, cycling, bus and train.

18 - To encourage efficient patterns of movement, promote sustainable travel of transport and ensure good access to services

++

S-LT

Low uncertainty, Reversible

Likely significant effects:

The LPR would be expected to help ensure that residents and workers in Ipswich are able to move efficiently and relatively sustainably. Residents will be in proximity to services and facilities and so will rarely need to travel long distances. It is likely that they will be able to walk or cycle to most locations, whilst excellent access to bus and rail links will offer alternative sustainable modes of transport.

Recommendations:

Residents and employees may be less willing to walk or cycle if their route is deemed unsafe. It is recommended that where pedestrian and cycling links are provided, careful consideration should be given to the safety of these routes, such as by not restricting cycle lanes to narrow strips on busy roads. High quality, attractive and safe routes, that could frequently tie in with the GI network, would encourage good rates of cycling and walking.

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

++

S-LT

Low uncertainty, Reversible

Likely significant effects:

It is considered to be likely that, overall, the LPR would facilitate a significant enhancement to residents and workers' access to digital infrastructure. Most new residents will be situated in urban and central locations where such access is very good and where the enhancement of infrastructure would benefit large numbers of people. It is also expected that new infrastructure would be provided through Policy DM33 on the delivery and expansion of the network.

Recommendations:

Digital infrastructure enhanced or provided in the Borough should be able to adapt to future technologies such as 5G.


8.3 Cumulative and synergistic effects with development in neighbouring authorities

8.3.1 The assessment of cumulative effects involved considering all relevant plans and programmes. Some of the development proposed in the Ipswich LPR is near the Borough's boundary, on the other side of which are, on occasion, sites being considered for development in neighbouring authorities. The following plans were factored into the cumulative effects assessment:

  • Babergh and Mid Suffolk District Council – Joint Local Plan; and
  • Suffolk Coastal Local Plan Review.
    1. Neither of the above plans are finalised or adopted and are currently in the process of determining where to situate new development. Of the Babergh and Mid Suffolk Joint Local Plan, residential and employment sites from the SHELAA that are potential allocations adjacent to the north and western perimeters of Ipswich, and that have not been discounted or deemed unreasonable, were identified. It is largely uncertain if any or all of these sites would be allocated and so in line with the precautionary principle, they will each be considered in the cumulative effects assessment. This includes:
  • SS0721 - Former Sugar Beet Factory Site, Sproughton Road (size unknown, employment use);
  • SS0299 - Land at Poplar Lane, 12ha for 475 dwellings; and
  • SS0191 - Land west of London Road (A1214) and east of Hadleigh Road, 31.4ha for 700 dwellings.
    1. Of the sites being considered for development in the Suffolk Coastal Local Plan review, the following sites were identified in the potential allocations list and, at the time of writing, it is considered to be likely that they will be allocated for the described development and will therefore be included in the cumulative effects assessment:
  • SCLP12.24 Land at Humber Doucy Lane, approximately 8ha for 150 dwellings;
  • SCLP12.22: Land off Lower Road and Westerfield Road, at least 24.5ha of country park in association with Ipswich Garden Suburb; and
  • SCLP12.64: Land at Lower Road Westerfield, 2.45ha for 45 homes and open space.
    1. A number of other sites were identified as reasonable alternatives in the Suffolk Coastal Local Plan Review. They are currently not scheduled for allocation and are unlikely to be so, generally because the local authority has determined other sites to be more appropriate for allocation. For the Suffolk Coastal LPR, growth in the east of Ipswich area is not central to the plan strategy. These alternative sites will not be included in the cumulative effects assessment. This will be revisited later in the SA process to ensure the cumulative effects assessment factors in the correct set of allocated sites in neighbouring authorities as these may be subject to change.
    2. The results of the cumulative effects assessment of proposals in the Ipswich LPR in combination with the above listed sites in neighbouring authorities is presented in Table 8-2.

Table 8-2: Cumulative and synergistic effects of proposals in the LPR with development planned in neighbouring authorities

Key:

++

Major positive effect (significant)


+

Minor positive effect


0

Neutral effect


?

Uncertain effect


-

Minor adverse effect


--

Major adverse effect (significant)








SA Objective

Overall score

Duration & uncertainty

Commentary

1 - To reduce poverty and social exclusion

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S-LT

Medium uncertainty, Reversible

Likely significant effects:

Sites currently being considered (i.e. identified through the SHELAA) for development in the Babergh and Mid Suffolk Plan would see approximately 1,175 new homes near Ipswich's south-western perimeter in proximity to Sproughton, as well as new employment land.

Development currently planned near Westerfield in the Suffolk Coastal Plan, as well as near Humber Doucy Lane, would also see several hundred homes in these locations.

In each case, the planned development in neighbouring authorities is in proximity to residential sites currently allocated in the Ipswich Plan, including the Ipswich Garden Suburb and the Humber Doucy Lane Broad Area.

It is considered to be likely that, cumulatively and synergistically, the development proposed in each authority would help to situate new residents in proximity to other residents and within coherent communities that also have excellent access to jobs and services and will thus combine to help combat the risk of social exclusion.

Recommendations:

When determining the accessibility of services, facilities and jobs for new residents, the development planned in neighbouring authorities should be considered. Cross-boundary efforts to ensure residents are able to move freely to access services and facilities in settlements or neighbourhoods, as well as jobs, such as via pedestrian or cycle routes, just outside the Borough border would help to combat exclusion and poverty.

2 - To meet the housing requirements of the whole community

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S-LT

Low uncertainty, Reversible

Likely significant effects:

It is considered to be likely that districts neighbouring Ipswich will have enough land to accommodate enough housing to satisfy their respective needs, as indicated by their respective SHELAAs.

Recommendations:

Cross-boundary cooperation may be needed to ensure there is adequate affordable housing provision on a settlement by settlement basis.

3 - To improve the health of the population overall and reduce health inequalities

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S-LT

Medium uncertainty, Reversible

Likely significant effects:

It is considered to be likely that development in neighbouring authorities would help to establish coherent communities that benefit the mental wellbeing of residents. In some cases, it is unclear if new residents in sites in neighbouring authorities would rely on health services such as GP surgeries or hospitals in Ipswich.

SCLP12.22 in Suffolk Coastal includes the provision of 24.5ha of open space which will help to ensure residents of Ipswich Garden Suburb have good access to open and green spaces as well as a diverse range of natural habitats.

The Humber Doucy Lane area would be expected to result in the loss of greenfield land and open spaces, that may reduce local residents' access to such spaces. Site SCLP12.24 in Suffolk Coastal may exacerbate this impact.

Recommendations:

Residents in Ipswich sites that are in proximity to sites in neighbouring authorities should be provided with opportunities to engage with their local community and to socialise with neighbours. This may require carefully planned pedestrian and cycle routes in to neighbourhoods in Mid Suffolk, Babergh or Suffolk Coastal districts.

4 - To improve the quality of where people live and work

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S-LT

Medium uncertainty, Reversible

Likely significant effects:

Cumulatively, a large quantity of development is being considered in proximity to Ipswich. In some cases, this could be a source of noise, air and light pollution as a result of the extensive construction works and the increase in road traffic from new residents.

Sites in neighbouring authorities would also result in a reduction in greenspaces and vegetation that currently contribute towards high visual attractiveness and amenity in the local area. Conversely, a potential impact of nearby development in neighbouring authorities may be that new infrastructure to the area and high-quality GI networks is more viable. It is uncertain the impact these sites would have in combination on safety or crime – the larger increase in local residents may potentially increase the scope for crime to occur or could potentially enable higher rates of natural surveillance that alleviate the risk of crime.

Recommendations:

Development should be designed in a manner that enables high rates of natural surveillance to reduce the risk of crime. The provision of GI throughout new developments can help to filter out air pollutants and provide a screen from light pollution.

5 - To improve levels of education and skills in the population overall

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S-LT

Medium uncertainty, Reversible

Likely significant effects:

It is currently unknown if sites in neighbouring authorities would include new educational facilities. In line with a precautionary approach, it is assumed that many new residents in sites adjacent to the perimeter of Ipswich will rely on schools in Ipswich, which would place greater pressure on the capacity of Ipswich's schools and could, in some cases, limit Ipswich residents' access to school places.

Recommendations:

When determining the capacity of schools and education facilities, development planned in neighbouring authorities may need to be factored into the equation. Where new facilities or expanded facilities are required, these should be accessible via walking, cycling and other sustainable travel modes for residents in neighbouring authorities relying on these schools.

6 - To conserve and enhance water quality and resources

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S-LT

Medium uncertainty, Reversible

Likely significant effects:

Some of the sites currently allocated for development in neighbouring authorities are adjacent to waterbodies that sites in Ipswich are also adjacent to, including the River Gipping and small ponds and streams near Humber Doucy Lane. All of the development in these locations pose a cumulative risk to the quality of water, such as due to altered surface runoff rates or contamination during the construction phase. It is also expected that all sites in combination would result in a net increase in water consumption across the ISPA.

Recommendations:

Best efforts will be needed to avoid contamination of the River Gipping. Requiring development on a site by site basis to manage this risk may not adequately account for the cumulative risk of all sites in combination. SuDS and GI should be incorporated into the development of sites in Ipswich, preferably in a coherent network that also integrates with the network in neighbouring authorities to maximise its water protection service.

7 - To maintain and where possible improve air quality

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S-LT

Medium uncertainty, Permanent

Likely significant effects:

It is considered to be likely that development proposed in neighbouring authorities would cumulatively result in a net increase in air pollution in the local area, largely as a result of increases in local road traffic. Sites in Suffolk Coastal generally have good access to railway stations and bus links, but sites in Babergh and Mid Suffolk are somewhat more isolated from sustainable transport links whilst having excellent access to the strategic road network.

Recommendations:

Consideration should be given to the accessibility and capacity of public transport links following the proposed development in Ipswich as well as neighbouring authorities. Electric car charging points should be provided for in Ipswich that can be used by those driving from neighbouring authorities into Ipswich. Green infrastructure should be incorporated into development in a manner that helps to filter out air pollutants, particularly in locations where traffic and congestion may be most liable to be exacerbated by all sites in combination and preferably in a coherent network with GI in neighbouring authorities that maximises its air filtering service.

8 - To conserve and enhance soil and mineral resources

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S-LT

Low uncertainty, Permanent

Likely significant effects:

Development proposed in neighbouring authorities in combination with that which is proposed for Ipswich would be expected to result in a permanent net loss of soils across the ISPA. In particular, soils in the region of the proposed Ipswich Garden Suburb in combination with development planned near Westerfield in Suffolk Coastal would be adversely impacted with large-scale excavation, erosion and compaction likely with contamination also a risk. Similar impacts, but to a lesser extent, would be expected as a result of development in the Humber Doucy Lane area.

Recommendations:

Sustainable soil management practices should be adopted during the construction phase of development to minimise rates of excavation, erosion and compaction and to reduce the risk of contamination. Where feasible, excavated soils should be reused. A coherent GI network that extends throughout and beyond Ipswich, comprised of semi-natural and a diverse range of species and that is incorporated into developments would help to protect and enhance the quality of soil fertility and structure underneath.

9 - To promote the sustainable management of waste

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S-LT

Medium uncertainty Permanent

Likely significant effects:

It is expected that development in Ipswich, in combination with development planned in neighbouring authorities, would result in a net increase in waste sent to landfill or incineration. It is uncertain the extent to which development in neighbouring authorities would provide the opportunities to reuse existing materials or buildings. There is a risk, although this is largely uncertain, that the large quantity of development proposed for the Ipswich Garden Suburb and in Suffolk Coastal near Westerfield could cause issues related to the capacity of waste services.

Recommendations:

All new businesses and residents should have good access to opportunities for recycling household and business waste.

Where feasible, low-impact, recycled and reused materials should be encouraged as much as possible.

10 - To reduce emissions of greenhouse gases from energy consumption

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S-LT

Medium uncertainty, Permanent

Likely significant effects:

Development proposed across the ISPA would cumulatively lead to a major increase in GHG emissions as a result of the construction and occupation of the large number of homes and businesses and the subsequent increase in traffic likely associated with this. Development near Westerfield and in the Ipswich Garden Suburb has good access to Westerfield Railway Station. Access to bus links is currently poor but it is expected new bus links would be provided within the new suburb. Given the provision of services and facilities within the Garden Suburb, most new residents in this region will be able to walk and cycle to access these. Development near Humber Doucy Lane as well as that near Sproughton could potentially be more isolated from services and facilities whilst also having limited access to public transport modes.

Recommendations:

New and existing residents should be provided with good access to bus, rail, cycle and walking routes, ideally within 500m of a bus stop with frequent services and within 2km of a railway station. Public transport modes should provide good access to areas throughout and beyond the Borough.

A coherent GI network that extends throughout and beyond Ipswich, comprised of semi-natural and a diverse range of species and that is incorporated into developments would help to provide a carbon capture and storage service. This GI network should also provide safe and attractive pedestrian and cycling links that encourages sustainable and efficient movement.

11 - To reduce vulnerability to climatic events and flooding

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S-LT

Low uncertainty, Reversible

Likely significant effects:

Development in neighbouring authorities could potentially lead to the loss of GI and tree canopy that reduces the natural climate cooling service provided by tree canopy and GI cover across the strategic planning area.

Recommendations:

A coherent GI network that extends throughout and beyond Ipswich, comprised of semi-natural and a diverse range of species and that is incorporated into developments and that leads to an overall increase in the tree canopy coverage would help to protect and enhance the climate cooling service.

12 - To safeguard the integrity of the coast and estuaries

O

S-LT

Medium uncertainty, Reversible

Likely significant effects:

Development in neighbouring authorities would not be expected to have a cumulative impact on coasts or estuaries, including the Stour and Orwell Estuary.

13 - To conserve and enhance biodiversity and geodiversity

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S-LT

Medium uncertainty, Reversible

Likely significant effects:

Development in Ipswich will predominantly be an opportunity to enhance the biodiversity value of sites, given their brownfield and often derelict status. Development in neighbouring authorities will more commonly be on greenfield land that results in the loss of habitats and could affect priority species. The Humber Doucy Lane broad location, in combination with the Humber Doucy Lane site in Suffolk Coastal would result in the loss of valuable greenfield land and potentially priority habitats in that area. The Ipswich Garden Suburb, in combination with sites allocated for development near Westerfield, would result in the loss of a large quantity of greenfield land in the area and could pose a risk to local protected species if identified through appropriate surveys.

Cumulatively, development across the ISPA would facilitate a large population growth. The increase in local residents and workers would be expected to increase the pressure on local nature reserves, wildlife sites, woodland and other green spaces due to the increased visitor pressure and footfall.

Recommendations:

Appropriate ecological surveys of sites should be carried out prior to development to establish the presence of protected species and habitats. Sites should be considered for the extent to which they contain land functionally linked with habitats outside the Borough.

A coherent GI network that extends throughout and beyond Ipswich, comprised of semi-natural and a diverse range of species and that is incorporated into developments and that is also designed to permit the movement of wildlife through high-quality and semi-natural corridors and stepping stones would help to protect and enhance biodiversity in and around Ipswich.

14 - To conserve and where appropriate enhance areas and assets of historical and archaeological importance

O

N/A, Low uncertainty, Reversible

Likely significant effects:

Cumulative and synergistic effects on the historic environment, caused by development in neighbouring authorities in combination with development in Ipswich, are considered to be unlikely.

15 - To conserve and enhance the quality and local distinctiveness of landscapes and townscape

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S-LT

Medium uncertainty, Reversible

Likely significant effects:

Development in neighbouring authorities would be expected to have a cumulative impact on the character of the local landscape, including near Humber Doucy Lane, north of Ipswich Garden Suburb and near Sproughton. This is primarily due to the conversion of visually attractive greenfield land containing green landscape features being converted to the urban built form. Cumulative and synergistic effects on the AONB would not be expected.

Recommendations:

Development near the perimeter of neighbouring authorities and development planned there should seek to adopt a high-quality design and appropriate architecture, with GI incorporated throughout the development, to minimise adverse impacts on the local character. A coherent GI network that extends throughout and beyond Ipswich, comprised of semi-natural and a diverse range of species that is incorporated into developments and that is also designed to be visually attractive and links with the natural landscape should be sought.

16 - To achieve sustainable levels of prosperity and growth throughout the plan area

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S-LT

Low uncertainty, Reversible

Likely significant effects:

It is expected that development proposed in Ipswich and neighbouring authorities would help to provide a major boost to local prosperity and growth. It is expected that new residential development in neighbouring authorities would help to increase footfall in central and shopping areas of Ipswich. The creation of employment land in neighbouring authorities would also provide residents of Ipswich with new employment opportunities that are in accessible locations.

17 - To maintain and enhance the vitality and viability of town and retail centres

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S-LT

Low uncertainty, Reversible

Likely significant effects:

It is expected that development proposed in Ipswich and neighbouring authorities would help to provide a major boost to central areas in Ipswich, including shopping, retail, tourism, culture and leisure industries. Ipswich town centre is highly permeable and accessible via various modes for residents in neighbouring authorities and they will be likely to visit Ipswich and its central locations regularly, increasing footfall in these locations and helping to ensure they are viable, vital and prosperous.

18 - To encourage efficient patterns of movement, promote sustainable travel of transport and ensure good access to services

+

S-LT

Low uncertainty, Reversible

Likely significant effects:

Development near Westerfield and in the Ipswich Garden Suburb has good access to Westerfield Railway Station. Access to bus links is currently poor but it is expected new bus links would be provided within the new suburb. Given the provision of services and facilities within the Garden Suburb, most new residents in this region will be able to walk and cycle to access these. Development near Humber Doucy Lane as well as that near Sproughton could potentially be more isolated from services and facilities whilst also having limited access to public transport modes.

Recommendations:

A coherent GI network that extends throughout and beyond Ipswich, comprised of semi-natural and a diverse range of species should be incorporated into developments to provide safe and attractive pedestrian and cycling links that encourages sustainable and efficient movement.

Residents should have good access to frequent bus services, preferably within 500m of their home, and would ideally be within 2km of a railway station. It is likely that residents near Sproughton will rely on Ipswich Railway Station, and residents near Humber Doucy Lane will rely on Derby Road or Westerfield railway stations, within Ipswich and so good pedestrian, cycling and bus links between these areas is required.

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

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S-LT

Low uncertainty, Reversible

Likely significant effects:

With sites in Ipswich in proximity to sites in neighbouring authorities, new digital infrastructure delivered in the area has the potential to benefit larger numbers of residents. The greater quantity of development near Sproughton, Westerfield and the Humber Doucy Lane area may also make delivering new digital infrastructure, or enhancing existing infrastructure, in these locations more viable.

Recommendations:

Newly delivered or enhanced digital infrastructure should be able to provide high speed or full fibre internet speeds to nearby residents and able to adapt to future technologies such as the provision of 5G. Given the large quantity of development in some locations, particularly near the proposed Garden Suburb and Westerfield, the local digital infrastructure will need to have a large capacity.







[4] WSP / Parsons Brinckerhoff (May 2016) Ipswich Core Strategy Air Quality Report

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