Final Draft Ipswich Local Plan 2018 - 2036 Sustainability Appraisal Report (SEA and SA)

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. Arcadis Consulting (UK) Ltd. ('Arcadis') have been commissioned by Ipswich Borough Council ('the Council') to prepare a combined Sustainability Appraisal (SA) and Strategic Environmental Assessment (SEA) of the emerging Final Draft Ipswich Local Plan.
2. The Final Draft Ipswich Local Plan is presented in two documents:

• Core Strategy and Policies DPD Review; and
• Site Allocations and Policies (incorporating IP-One AAP) DPD.

3. 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 SA Report provides an appraisal of the likely sustainability effects of both documents of the Final Draft Ipswich Local Plan (the Plan), to accompany consultation.
4. SA is a process for assessing the social, economic and environmental effects 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. The law states that the SA must also comply with requirements of the European SEA Directive. For the purpose of readability, this SA/SEA Report, is referred to as the SA Report.
5. 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 Plan, who will also be considering other evidence documents alongside the SA. This involves the ongoing appraisal of the Plan 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 SA

6. The SA process commenced in August 2017 with an SA Scoping Report prepared by the Council, which set out the scope and level of detail of the SA. The Scoping Report was updated in February 2018, in response to comments from the general public and statutory consultees received during the ten-week public consultation period. The Scoping Report:

• Reviews other relevant programmes, plans and strategies that have an influence on sustainability to establish the policy context of the Plan and the SA;
• 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 policies and policy options and the overall predicted effects of the plan.

7. The Scoping Report was consulted on between 18^th August and 30^th 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.
8. An interim SA report was prepared in January 2019 that accompanied the Preferred Options Regulation 18 consultation on the Plan.

1. Policy context

9. 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 Plan 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.

2. Environmental baseline

10. Among the important decisions considered during the Scoping Stage 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.

3. Key sustainability issues and opportunities

11. 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).

4. The SA Framework

12. 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 Plan is assessed for its likely effects 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?

13. An Interim SA Report was prepared in January 2019 to accompany Regulation 18 consultation on Preferred Options Plan. This Interim SA Report provided assessments that predicted and evaluated the likely sustainability effects of the Council's preferred options and their alternatives for the Plan. These assessment results, which essentially indicate the sustainability costs and benefits of each policy and site option, helped to inform the Council's decision-making process with regards to which options to pursue in the Plan.
14. Following on from the Interim SA stage, this Publication SA Report has been prepared. This Report updates the assessments made in the previous iteration of the draft Ipswich Local Plan (Regulation 18), to reflect changes made to the Final Draft Local Plan (Regulation 19).. The assessments in this report, and the recommendations alongside them, have assisted with the Council's decision-making process when refining the defining the sites and policies proposed in the Final Draft Ipswich Local Plan (the final stage and formal stage of plan-making before submission to the Secretary of State for Examination)..
15. The Final Draft Ipswich Local Plan has been assessed for its compatibility with, or likely effects on, each SA Objective. The following elements have been assessed in order to predict and evaluate their likely impacts on the SA Framework:

1. A Vision for Ipswich as well as Strategic Objectives, the achievement of which would deliver the Vision;
2. Growth strategy - the amount of development that should take place in Ipswich (including residential development and economic development)
3. Spatial strategy – an overall distribution of development;
4. Core Strategy Policies;
5. Development Management Policies; and
6. Site policies (including policies that determine the specific types and quantities of development that should take place at specific locations in the Borough).

16. In order to satisfy the requirements of the SEA Directive and the SEA Regulations and in order to ensure legal compliance in light of relevant case law, the Council has considered reasonable alternatives to each of the proposals in the Plan. Each of the reasonable alternatives considered by the Council has also been considered for its likely sustainability effects using the SA Framework. Preferred options and reasonable alternatives have been assessed using the same methodology and to the same level of detail. The common approach to assessments for all options and alternatives has allowed the Council to compare the sustainability performance of different options and make evidence-led decisions. The Council's approach to the consideration of reasonable alternatives has been in accordance with all relevant requirements of the Directive, Regulations and case law.
17. 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 effects;
• The cumulative nature of effects;
• The transboundary nature of effects; and
• The value and vulnerability of that which is being affected.

18. Based on the assessment results, this SA Report also provides recommendations for either enhancing a proposal's positive effects, or measures for avoiding or reducing likely adverse effects.

SA Assessment Results

1. Vision and Objectives

19. 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 Final Draft Ipswich Local Plan was found to be highly compatible with the SA Framework and would be expected to help ensure the plan deliver socially, economically and environmentally sustainable land-uses and development until 2036.

2. Growth Strategy

20. Fundamental to the Plan is the total quantity of development the Final Draft Ipswich Local Plan will seek to secure in Ipswich (i.e. the number of homes to meet objectively assessed needs for the Borough and the number of jobs created in Ipswich over the Plan period).
21. The employment and housing growth proposed in the Final Draft Ipswich Local Plan is the result of a lengthy, evidence-led and objective approach taken by the Council to calculate Ipswich's housing needs over the Plan period and to view this in terms of what the Borough can accommodate and what would deliver the most sustainability benefits.
22. In 2017, Ipswich was considered to have an Objectively Assessed Need (OAN) of 11,420 new dwellings over the Plan period of 2014 – 2036.
23. Since the Preferred Options consultation, the method of calculating housing need was further refined by the Government. Applying this approach reduced the housing needs for Ipswich from a total of 8,622 dwellings over the Plan period to a total of 8,010 dwellings over the Plan period.
24. Alongside the housing need the Council have explored the potential jobs growth in the Borough, including the likely minimum number of new jobs required to support the growing population as well as opportunities for maximising local economic growth and transformation. 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).

25. Since the Preferred Options consultation, it has been identified that the job calculations from the latest EEFM (August 2017) have forecast a significant reduction in the jobs growth in the Borough when compared to the originally used 2016 EEFM calculations. This equated to a 40% reduction (15,580 jobs to 9,318 jobs) and due to this significant change, it was deemed appropriate to revise the target. Based on the latest 2017 EEFM, the Council is seeking to deliver at least 9,500 new jobs for the 2018 – 2036 period through the Final Draft Ipswich Local Plan. This also means that there is a better balance between dwelling numbers proposed for the Borough and forecasted new jobs.
26. After identifying the minimum housing and employment needs for the Borough, the Council explored a range of options of various levels of growth that meet or exceed the minimum needs. The consideration of alternatives enabled the Council to weigh up the costs, risks and benefits of different quantities of development and to select a strategy that would be achievable, deliverable, would satisfy local employment needs and would be as sustainable as possible. Overall, the following growth scenarios have been explored by the Council:

• 8,622 homes and 15,580 jobs;
• 11,420 homes and 19,040 jobs;
• 25,837 dwellings and 32,376 jobs;
• 30,143 dwellings and 32,376 jobs;
• 8,010 homes and 9,500 jobs;
• 8,838 homes and 9,500 jobs;
• 8,802 homes and 9.500 jobs; and
• 9,612 homes and 15,580 jobs.

27. Each of these growth scenarios were also assessed in the SA to determine their likely sustainability impacts. The full results of this process are presented in Appendix C of this SA Report.
28. The appraisal identified a range of potential positive and adverse effects, with often mixed results identified against most SA Objectives. All options would be expected to help ensure that housing and employment needs in Ipswich to 2036 can be met, and this would make a significant contribution towards transforming the Borough and combating rates of homelessness, unemployment, deprivation, inequality and poverty. 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. Lower quantities of growth could likely be entirely accommodated within the Borough, whilst higher levels of growth could result in some of the growth taking place in neighbouring authorities, most likely on greenfield sites.
29. Generally speaking, it was considered that the lower the quantity of development being considered, the more feasible it would be to avoid adverse effects 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.
30. Although alternatives were assessed, the Council's proposed approach in the Final Draft Ipswich Local Plan is to seek to secure a minimum of 8,010 dwellings over the Plan period as well as the creation of at least 9,500 new jobs.

3. Spatial Strategy

31. In order to deliver development through the Plan, the Council has considered a range of different spatial distribution options. These are high-level distribution patterns. Given the tightly drawn boundary around the Borough, the range of spatial options available to the Council that could accommodate the proposed level of growth (8,010 dwellings and 9,500 new jobs) 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;

32. Spatial Options 4, 5 and 6 were options that applied to the administrative area of Suffolk Coastal District Council (now within East Suffolk Council). (This has been considered because of the initial joint working on sustainable appraisal between the two authorities and the setting of a joint baseline.) 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.

33. Each of these spatial options were assessed in detail in the SA to identify their likely sustainability impacts, in order to inform the Council's decision-making process. The results of these assessments are presented in their entirety in the appendices of this report.
34. 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 effects on sensitive natural landscapes or important wildlife areas.
35. 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 effects 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 sustainable transport modes here.
36. The Spatial Strategy proposed in the Final Draft Ipswich Local Plan is a combination of several of the Spatial Options, but mostly aligns with Spatial Option 1.

4. Core Strategy Policies

37. The Final Draft Ipswich Local Plan Core Strategy and Policies document presents a range of Core Strategy Policies related to the themes of 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 effects for all SA Objectives. It is highly likely that these policies will ensure that the housing and employment needs of Ipswich's growing and varied population are satisfied. In so doing, the Core Strategy Policies would make a significant contribution towards reducing homelessness, deprivation, inequality and poverty in Ipswich whilst enhancing community cohesion, digital connectivity for people and businesses and protecting and enhancing the Borough's rich array of built assets and historic areas. The Core Strategy Policies are also predicted to result in significant positive effects on the mental and physical health and wellbeing of local people as well as the quality, quantity and accessibility of education and skills-learning opportunities.
38. The scale of growth proposed in the Core Strategy Policies poses a risk to the natural environment in Ipswich. However, by taking the strategic approach identified in the Final Draft Ipswich Local Plan to both housing and job numbers, the impact of risk is reduced. There is though, a large increase in the number of homes that would result in net loss of greenfield land and valuable soils (both ecologically and agriculturally valuable). In comparison, employment land sites are considered to make a highly efficient use of the land resource, with most of them being situated on brownfield land. New homes, residents, businesses and employees would also be expected to make it increasingly difficult to achieve carbon dioxide emission reduction targets and quality improvement targets, primarily due to the energy consumption and car-use of local people. Core Strategy Policies seek to minimise this and rightly recognise the importance of improving air quality, particularly within Air Quality Management Areas, where air quality is dangerously poor; as well as carbon dioxide emissions, given the urgent need to transition towards carbon neutral societies. The scale of growth would also be expected to make it increasingly difficult to reduce the total amount of waste sent to landfill.
39. Whilst the scale of growth poses a major threat to biodiversity in Ipswich, the Spatial Strategy, combined with various Core Strategy Policies, would minimise this risk and, , will see a minimum biodiversity net gain being achieved. Crucial to achieving this will be careful monitoring of the quality and connectivity of Ipswich's ecological network as well as the total tree canopy.

5. Development Management Policies

40. The Final Draft Local Plan Core Strategy and Policies document presents policies that have been designed to manage development in Ipswich. Development proposals that do not accord with these policies will be less likely to be supported or granted permission by the Council. Each of these policies has been assessed in detail in the appendices of this report.
41. Overall, the Development Management Policies would be expected to make a major contribution towards enhancing the sustainability of development in Ipswich. In particular, significantly positive effects were identified for SA Objectives related to enhancing the quality and quantity of homes in Ipswich; protecting water resources; improving air quality; reducing the Borough's carbon footprint; protecting local people from the risk of flooding; achieving biodiversity net gains; protecting distinctive natural landscapes and the character of townscapes; and achieving sustainable economic growth.
42. In practice, it is expected that the range of Development Management Policies presented in the Final Draft Ipswich Local Plan would help to ensure that negative impacts on the natural environment potentially arising from the construction and occupation of 8,010 new homes, alongside the creation of 9,500 new jobs, would be avoided or minimised.

6. Site Policies

43. The Site Allocations and Policies Document of the Final Draft Ipswich Local Plan presents 16 Site Policies. The overall intention of these policies is to identify specific parcels of land within the Borough at which defined quantities of specific types of development would, in principle, be supported by the Council (only where proposals for such development conforms with Core Strategy and Development Management Policies). The range of sites identified and allocated by the Council would be expected to ensure that the development needs of Ipswich over the Plan period can be satisfied.
44. The predicted and evaluated sustainability effects of the sites allocated under the Site Policies in the Final Draft Ipswich Local Plan varies from site to site depending on the scale and type of development proposed in relation to the location and the proximity to constraints and assets. Generally speaking, residential sites are located within existing communities benefitting from good access to key services, amenities and facilities. The sites would therefore be expected to help combat the risk of social exclusion for local people whilst ensuring they can pursue healthy, active and high-quality lifestyles. Residents would be likely to only need to travel short distances to access key services, amenities and facilities, as well as employment opportunities, and would have good sustainable transport modes for when they do travel. In so doing, the locations of the sites should enable relatively efficient lifestyles for residents.
45. A large portion of the allocated sites comprise brownfield land in urban locations. Development in these locations delivers a range of sustainability benefits, including an efficient use of land with soil losses minimised; development in-keeping with the local character; minimising impacts on biodiversity and ecological connectivity, with good opportunities for biodiversity net-gains and more efficient energy and utilities networks. However, it is important to note that, whilst development on a brownfield site in an urban location provides these benefits above development on greenfield sites in countryside locations, it is likely that the proposed development at each site would still result in a net increase in carbon emissions, air pollution, water consumption, energy consumption, and transport movements, in relation to existing levels. Furthermore, situating residents in intensely urban locations can be expected to expose these residents to relatively high levels of noise, air and light pollution, such as where sites are situated adjacent to one or more busy roads.

Cumulative effects

1. Cumulative effects of all proposals in the Final Draft Ipswich Local Plan

46. The policies and site allocations proposed in the Final Draft Ipswich Local Plan 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. Cumulative effects of proposals in the Final Draft Ipswich Local Plan with development in neighbouring authorities

47. Following the assessment of cumulative effects caused by all Final Draft Ipswich Local Plan proposals in combination, an assessment of the cumulative effects of proposals in the plan in combination with development planned in neighbouring authorities was also carried out.
48. Major positive cumulative effects of all proposals in the Final Draft Ipswich Local Plan 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.
49. Minor adverse cumulative effects of all proposals in the Final Draft Ipswich Local Plan 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.
50. 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

51. The assessment of proposals in the Final Draft Ipswich Local Plan 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.
52. Perhaps the most important, effective and comprehensive measure recommended by the SA is for the Council to ensure Ipswich benefits from an extensive, high-quality and connected green infrastructure network designed and managed in a way that delivers benefits to nearly all elements of sustainability, including air quality, climate change (including mitigation as well as adaptation), biodiversity, water, natural resources, landscape and townscape character, economy, community and human health.

Monitoring

53. This SA Report also proposes a Monitoring Framework. The Monitoring Framework is proposed to measure the performance of the Final Draft Ipswich Local Plan , 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.

54. 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 effects of the Final Draft Ipswich Local Plan, it will also be necessary to monitor changes to the environmental, social and economic context and baseline conditions.
55. 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 Monitoring Framework in this chapter would be incorporated into the AMR.
56. The 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.