Support

Representation ID: 424

Received: 10/03/2014

Respondent: Environment Agency

We are largely in agreement with the findings of the SA Report and have no specific or general comments to make.

Object

Representation ID: 429

Received: 10/03/2014

Respondent: Suffolk Coastal and Waveney District Councils (East Suffolk)

The NPPF states that broad locations can be identified for development late in the plan period, but the broad location of 'Ipswich Policy Area' (IPA) provides no clarity as to the proportion of dwellings expected to be provided in each neighbouring authority. The SA does not provide any assessment of broad locations or cumulative effects on areas with known constraints. In light of the limited land available in Ipswich, the SA should consider all reasonable alternatives e.g. increasing densities, and consider the plans already adopted by neighbouring authorities and developments in the IPA already established in principle.

Support

Representation ID: 755

Received: 10/03/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

The additional text on open spaces, green infrastructure, improved ecological networks and tree canopy cover are supported ( Para 4.2.1).

Object

Representation ID: 756

Received: 10/03/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

Hyder has failed to see the implications of changes to the CS; the removal of any PDL target is a major change. Development of the greenfield Garden Suburb will reduce development of brownfield sites which should be the priority. A suburb creates more traffic than sites near to existing employment and will therefore impact upon environmental objectives. A specific target for jobs in Ipswich not the Policy Area is also required in order to have any meaning. The implications in switching from a jobs led to a housing led strategy are huge and must be assessed.

Object

Representation ID: 798

Received: 12/06/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

The SA/SEA process requires an examination of the baseline information of the Borough as it is now together with data on how it may change in the future. The CS and its SA must therefore be based on the best data available, which is not the case as it fails to utilise the most recent DCLG or EEFM 2013 forecasts. Both the CS and this SA are therefore unsound.

Object

Representation ID: 799

Received: 12/06/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

The SA must be revised to take account of new Governmental guidance on the NPPF, issued following the Ministerial Statement of 6th March 2014. Changes include: issuing guidance on flood risk; clarifying that local plans can be sound where authorities cannot identify housing land for years 11-15; allowing windfalls to be counted over the whole plan period and student/older persons' housing and the reuse of empty homes to be included when assessing housing need; ensuring that infrastructure is provided to support new development; stressing the re-use of brownfield land; and clarifying the issue of prematurity in relation to draft plans.

Object

Representation ID: 800

Received: 12/06/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

Sections 2.3.9 and 2.3.12 fail to identify from the 2013 Suffolk Growth Strategy (sections 2.26, 4.2, 4.4 & 4.5 refer) the need to 'transform skills from a growth barrier to a growth stimulus' and 'Boost educational attainment, aspiration and employability'.

Object

Representation ID: 801

Received: 12/06/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

Table 2-2 There are serious flaws/omissions in this summary of sustainability issues and opportunities that need to be corrected, especially in relation to the use of obsolete data. E.g. it needs to better represent low education standards in Ipswich, not underplay the issue; use better health data e.g. from AMR; address wastewater issues; acknowledge that air quality is worsening in Ipswich and factor in the effect of traffic from the Northern Fringe; acknowledge that Ipswich is not well connected; use better data on pay/benefits; address worsening deprivation; and include empty homes and stock condition data.

Object

Representation ID: 802

Received: 12/06/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

Table 2-3. Suggest improvements to objectives and indicators. See full text, but examples include: ET1 should include an indicator to measure congestion as the main cause of air pollution. ET2 the key issue is whether development will harm soil resources/quality which Hyder have omitted. HW1 better indicators would be levels of physical activity and GP registrations for depression. ER1 should ask whether developments will improve existing areas of deprivation. ER2 should add indicators for number of long term unemployed and average wage. ER3 should look at privately rented houses falling below EPC rating 'E'. Consider consequent changes to Table 2-4.

Object

Representation ID: 803

Received: 12/06/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

Paragraph 2.3.27 There will obviously be an increase of traffic during the construction / operation of new residential development associated with an increase of inhabitants and their future transport requirements, therefore this will obviously affect local air quality and climate change. This paragraph needs to be amended accordingly. If not please justify why Hyder thinks there might be no increase in traffic at all.

Object

Representation ID: 804

Received: 12/06/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

Paragraph 2.3.25 These are not "uncertainties" but likely outcomes unless further mitigation steps are implemented. The SA underestimates the impact of Objective ER3, which is incompatible with: ET1 improve air quality, ET2 conserve soil, ET3 reduce waste, ET4 reduce the effects of traffic upon the environment, ET6 limit and adapt to climate change, ET7 protect and enhance the quality of water and reduce the risk of flooding, and ET8: conserve and enhance biodiversity and geodiversity. E.g. under ET1 the number of AQMAs is increasing in Ipswich and the Northern Fringe will adversely impact on those north of the town centre.

Object

Representation ID: 805

Received: 12/06/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

Scoping Report and Paragraph 2.3.35 We have a number of concerns that our previous comments on the Scoping Report have not been adequately addressed and need to be revisited as a priority. We have included these in Appendix 1 using the original numbering with an explanation of our concerns in red. See appendix for full text.

Object

Representation ID: 806

Received: 12/06/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

Paragraph 2.4.4 The removal of a PDL target from Policy CS9 is a major change and therefore needs to be part of the SA.

Object

Representation ID: 807

Received: 12/06/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

Paragraph 3.1.1 The original SA was flawed because it did not look at alternatives to the Policies other than "do nothing". The SA of the revised CS must assess alternatives to the policies in order to be sound.

Object

Representation ID: 808

Received: 12/06/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

Table 3.1 Detailed comments on policies also need to be considered in the SA. The Table should assess changes to CS9. CS7 The most recent data should be used, and reliance on windfalls and neighbouring Local Authorities noted. CS10 The negative implications on brownfield development should be considered and wording on phasing looked at. CS13 Hyder should require that latest EEFM 2013 data are used, and assess growth areas relative to EEFM/NALEP strategic economic plan/Suffolk Growth Strategy. CS14 The SA should take better account of Ipswich Central's views on the Retail sector. CS17 Should check for and eliminate unintended consequences.

Object

Representation ID: 809

Received: 12/06/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

Table 4-1 The wider implications of the change to CS9 [brownfield target] needs to be considered alongside the options for keeping a target at a reduced level.

Object

Representation ID: 810

Received: 12/06/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

Paragraph 4.3.4 The SA needs to recognise that the CS needs to be better balanced to improve the lives of existing residents though redeveloping poor housing stock, tackling deprivation, reducing crime, improving health, getting people off benefits and back to work. The SA focuses too much on the advantages of new homes to the new residents and the averaging effect of these developments across Ipswich rather than on existing residents in existing wards who will remain disadvantaged and in need.

Object

Representation ID: 811

Received: 12/06/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

Paragraph 4.3.5 The policies do not consider the likely location of new homes to new employment sites, or that new residents in Ipswich Borough will have to commute outside of the Borough to new sites of employment. The policies do not consider the implication of having insufficient jobs to match the number of new residents looking for employment.

Object

Representation ID: 812

Received: 12/06/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

Paragraph 4.3.7 We are pleased that Hyder finally recognises the travel implications in relation to housing development of the Northern Fringe. However, this needs to be better reflected throughout its assessments.

Object

Representation ID: 813

Received: 12/06/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

Paragraph 4.3.10 The following recommendations are required: most recent population and employment data should be used and forecasts should be made across district boundaries; a firm jobs growth target will help focus delivery; a better balance between new jobs and homes is needed with homes built near jobs; less reliance on retail growth and better alignment with NALEP growth sectors; a PDL target should be reintroduced; CS10 and Table 8B should be revised to remove risk of unintended consequences; water supply and sewerage should be addressed; and more should be done to improve the lives of existing residents.

Object

Representation ID: 814

Received: 12/06/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

Table 4-2 The SA needs to recognise that the plan does little to improve educational standards in existing schools; little to tackle crime in existing wards, while promoting homes without jobs; little to improve health especially for those in poor housing stock; and nothing to redevelop/improve existing sub-standard housing. It uses obsolete jobs data and forecasts far exceed historic provision. Impacts on climate change will be negative and the potential sewage issues associated with growth have not been addressed. These omissions need to be rectified as a key objective.

Object

Representation ID: 815

Received: 12/06/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

Appendix E and Appendix F As the jobs and homes data used in the Core Strategy is obsolete, we have deferred commenting on the specific Impact Assessments until more recent data is utilised.

Object

Representation ID: 816

Received: 12/06/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

There are inconsistencies in the CS car parking policy and ambiguity in relation to the Bury Rd Park and Ride which the Site Allocations DPD assumes will be reopened and enlarged whilst the CS deletes the reference to a new park and ride (Page 74). The proposals for IP-One expand existing car park capacity but it is rarely insufficient to meet demand. This is also inconsistent with the aim for more people to walk and cycle and the reopening/extension of Bury Rd Park and Ride as indicated in the Site Allocations DPD. The SA needs to consider these issues accordingly.

Object

Representation ID: 817

Received: 10/03/2014

Respondent: Save Our Country Spaces

The evidence base is contested in relation to population projections and employment modelling. Previous rates of forecast jobs growth have not been delivered. The result is high youth unemployment and a low waged and low skilled economy. The Institute for Economics and Peace ranked it the 23rd most violent local authority area in England and Wales. The impacts of lack of employment need to be assessed by Hyder against statistics for problematic levels of crime and anti social behaviour. None of this is explored within the SA. SOCS support the NFPG analysis of the jobs issue.

Object

Representation ID: 834

Received: 10/03/2014

Respondent: Save Our Country Spaces

Assumptions, projections and estimates behind the growth agenda pursued since 2001 have not stood the test of time. New jobs have not materialised and Ipswich has lost manufacturing jobs. The result is a predominantly low waged and low skilled economy with a high level of youth need. Ipswich housing is relatively cheap and Ipswich has high urban densities compared to Suffolk. Thus Ipswich features adversely in terms of deprivation in the Institute for Economics and Peace study April 2013. In the SA, Hyder should examine the impacts of lack of employment together with crime and anti social behaviour statistics.

Object

Representation ID: 835

Received: 10/03/2014

Respondent: Save Our Country Spaces

There are policy gaps in the CSFR including transport. IBC has not allowed the known impacts of new development on the transport system to be enshrined in the Core Strategy and to be properly recognised and identified with adverse impacts on air quality, congestion, road safety covered by Section 106 agreements? Hyder need to revisit the saved policies from the 1997 Ipswich plan and take account of the policy direction contained in it. It contains some useful policy direction which has stood the test of time.

Object

Representation ID: 836

Received: 10/03/2014

Respondent: Save Our Country Spaces

There is no consistency with previous SA work [on CS10], in particular: regarding high levels of house building; mitigation measures required in the event of slow delivery at the Northern Fringe, not allowing multiple starts which could affect community networking; possible adverse impacts on Fynn Valley; the need to adopt the SPD before permission is granted for development on SA grounds; bringing forward the start date may undermine PDL delivery; the need for a country park as soon as development begins; and viability considerations impacting on open space provision.

Object

Representation ID: 837

Received: 10/03/2014

Respondent: Save Our Country Spaces

SOCS query the scoring in the SA. SA should be an iterative process but to date it has failed to be. SOCS are not reassured by the CSFR SA and its unconvincing rhetoric contained within the statements and conclusions. The Institute for Economics and Peace 2013 is not referenced or considered. The SA refers to 'revised policies also found to detract from some SA objectives with potential to have negative effects if no mitigation measures are out in place.' What contingencies are proposed if effective mitigation cannot be achieved, particularly around traffic, pollution and flood risk?

Object

Representation ID: 838

Received: 10/03/2014

Respondent: Save Our Country Spaces

SOCS are concerned about impacts on the existing population. If the Ipswich Garden Suburb is not successfully delivered or competently managed, there will be profound adverse consequences for future generations. A key requirement of sustainable development is that future generations will not be compromised (Brundtland).

Object

Representation ID: 839

Received: 10/03/2014

Respondent: Save Our Country Spaces

There is a lack of assessment and possible necessary mitigation for impacts on Suffolk Coastal District Council adjacent villages. There is a duty under the adopted Core Strategy and SA work to assess other LA growth plans and also mitigate pressures on local Ramsar sites and Country Wildlife Sites e.g. Fynn Valley which will be adversely impacted and put under intolerable pressure by the Northern Fringe development and development in other authority areas.