Object

Representation ID: 25666

Received: 11/03/2019

Respondent: Northern Fringe Protection Group

The Sustainability Assessment is incomplete and underplays many key issues. It needs to fully assess air quality impacts, the impacts of the additional road infrastructure required to prevent junctions reaching capacity and the impacts of the new sewage infrastructure that will be required to deliver the Core Strategy.

It needs to consider the adoption of Governments guideline target of 445 dwellings per annum as an option.

The SA needs to fully assess the implications of building on the Humber Doucy Lane site and whether delivering more homes in the Town Centre instead of retail might be more sustainable.

Object

Representation ID: 25684

Received: 11/03/2019

Respondent: Northern Fringe Protection Group

Too early to comment on the SA due to:
- No assessment of the proposed non-adherence to Government Guidelines for housing assessment and the alternative strategy;
- No SA of IBCs decision not to comply with air quality guidance;
- No SA of IBC's no adherence to government guidelines for AQAP and lack of target;
- No sewage infrastructure plan/ proposals and no impact assessment;
- No air quality modelling/ assessment of road and rail transport;
- No noise assessment of rail;
- No Sizewell C impact assessment;
- Review of Ipswich Retail;
Lack of appraisal of Humber Doucy Lane

Object

Representation ID: 25760

Received: 12/03/2019

Respondent: Natural England

The effects on local roads and the impacts on vulnerable sites from air quality effects on the wider road network should be assessed using traffic projections and the 200m distance criterion. The designated sites at risk from local impacts are those within 200m of a road with increased traffic, which feature habitats that are vulnerable to nitrogen deposition/acidification.

APIS provides a searchable database and information on pollutants. The results of the assessment should inform updates to the SA, which will need to identify appropriate mitigation to address any predicted adverse impacts to the natural environment.

Support

Representation ID: 25770

Received: 12/03/2019

Respondent: Natural England

Satisfied that the methodology and baseline information used to inform the scoping report appears to meet the requirements of the SEA Directive and guidance. Advise that further updates to the SA should ensure a robust assessment of the environmental effects of plan policies and allocations on statutorily designated sites and landscapes including the Orwell Estuary SPA, SSSIs and the Suffolk Coast and Heaths AONB, considering our advice and the findings of the evolving HRA. The SA will need to identify appropriate mitigation to address any adverse impacts to designated sites and landscapes and other aspects of the natural environment.

Object

Representation ID: 25839

Received: 12/03/2019

Respondent: Ravenswood Environmental Group

The traffic-light scoring system used is inaccurate insofar as it relates to various sites within Ravenswood. The SA is also not consistent with the SHEELAA which again uses a traffic-light scoring system and incorrectly scores sites which are known to have negative issues. The SA results of each of the sites pertaining to the Ravenswood locality are questioned (IP150a, IP150b, IP150c (omitted), IP150d, IP150e and IP152). The SA does not assess sites cumulatively. These sites cumulatively have a negative impact on the SPA and visitor pressure is already too great and associated management too poor to allow further development here.

Object

Representation ID: 25862

Received: 13/03/2019

Respondent: Save Our Country Spaces

The SA is unsound as it doesn't utilise the best available baseline and modelling data housing projections nor the ONS migration data, which significantly lower the objectively assessed housing need.

The earlier SA highlights the lack of information and uncertainty in assessing the effects on traffic, air quality and climate change of circa 4000 homes to be built and exposes a hole.

The plan fails to demonstrate that IBC can secure the required compliance.

The SA fails to take adequate account of issues including the viability of the IGS due to the severe impact on traffic and limited sewage infrastructure.

Object

Representation ID: 25863

Received: 13/03/2019

Respondent: Save Our Country Spaces

The SEA Directive requires that the assessment include identification of cumulative and synergistic effects including those produced by other neighbouring local authorities. The SA does not appear to take account of the cumulative effect of CSs Plans of neighbouring authorities with regard to housing, employment and especially transport/traffic and increased air pollution and traffic congestion.

Object

Representation ID: 25870

Received: 13/03/2019

Respondent: Save Our Country Spaces

The SEA Directive requires that the assessment include identification of cumulative and synergistic effects including those produced by other neighbouring local authorities. The SA does not appear to take account of the cumulative effect of CSs Plans of neighbouring authorities with regard to housing, employment and especially transport/traffic and increased air pollution and traffic congestion.

Object

Representation ID: 25871

Received: 13/03/2019

Respondent: Save Our Country Spaces

The SA is unsound as it doesn't utilise the best available baseline and modelling data housing projections nor the ONS migration data, which significantly lower the objectively assessed housing need.

The earlier SA highlights the lack of information and uncertainty in assessing the effects on traffic, air quality and climate change of circa 4000 homes to be built and exposes a hole.

The plan fails to demonstrate that IBC can secure the required compliance.

The SA fails to take adequate account of issues including the viability of the IGS due to the severe impact on traffic and limited sewage infrastructure.

Object

Representation ID: 25877

Received: 13/03/2019

Respondent: Save Our Country Spaces

It is too early to comment on the SA report for the following reasons:
1. No SA of IBCs decision not to comply with air quality guidance.
2. No SA of IBC's non-adherence to government guidance for AQAP and lack of target to reduce air pollution.
3. No traffic modelling without TUOC for the IGS development
4. No sewage infrastructure plan/ proposals.
5. No air quality modelling/ assessment
6. No air quality or noise assessment on rail.
Lack of appraisal of the impacts of building on land at Humber Doucy Lane

Updated SA is required to consider these issues.

Object

Representation ID: 26116

Received: 25/02/2019

Respondent: Elaine Noske

Fails take adequate account of transport, air quality, economy and wastewater issues; specifically that the possibility that the viability of the 'Garden Suburb', in combination with other cross-boundary proposals, may not be sustainably achieved due to the plans severe impacts on air quality, traffic and lack of sewage infrastructure. The plans are unsound and do not comply with the NPPF.

The "Climate Change" agenda is insufficiently addressed. Proposals are contrary to NPPF 10. Appears that environmental, social and economic effects of the plan(s) are inadequately/ inaccurately assessed against HRA and the SAs "Serious adverse effects" have not been properly identified.