Habitats Regulations Assessment at Preferred Options State - 150119
Object
Documents for Download
Representation ID: 25667
Received: 11/03/2019
Respondent: Northern Fringe Protection Group
The Habitats Assessment also needs to include 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.
Support
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Representation ID: 25742
Received: 12/03/2019
Respondent: Natural England
Satisfied that the HRA has provided a robust assessment of the Preferred Options. Natural England agrees that it is currently too early for the HRA to provide a conclusion that the plan will not lead to any adverse effects on European sites; however, we note that the screening of the Preferred Options has not identified any issues that flag a major concern that would significantly alter the direction and quantum of growth for the Borough. Welcomes recommendations for strengthening of policy wording and identification of key themes, including recreation, urbanisation, water and air quality, for detailed assessment through further stages.
Object
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Representation ID: 25761
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.
Object
Documents for Download
Representation ID: 25878
Received: 13/03/2019
Respondent: Save Our Country Spaces
The impacts of new sewage infrastructure that will be required to deliver the CS preferred options needs to be included in the HRA. Likewise, the impacts of the required traffic infrastructure identified by the traffic modelling to improve the road network to allow the sustainable delivery of the CS also needs to be included in the HRA. If no such assessments are included in the HRA then it needs to explain why they have been omitted.
Object
Documents for Download
Representation ID: 26076
Received: 13/03/2019
Respondent: CBRE
Agent: Mr Arwel Owen
The HRA which supports the Regulation 18 Local Plan consultation fails to offer clarity about the role of the Ipswich Garden Suburb Country Park within the RAMS regime, neither does it justify the exclusion of IGS sites from assessment under RAMS. The compartmentalisation of the IGS Country Park and RAMS should be justified if it is to maintained, notwithstanding our view that the two means of mitigation should be integrated under a single approach, allied to the provisions of ISPA3.
Object
Documents for Download
Representation ID: 26084
Received: 13/03/2019
Respondent: Mersea Homes Limited
Agent: Mr Arwel Owen
The HRA which supports the Regulation 18 Local Plan consultation fails to offer clarity about the role of the Ipswich Garden Suburb Country Park within the RAMS regime, neither does it justify the exclusion of IGS sites from assessment under RAMS. The compartmentalisation of the IGS Country Park and RAMS should be justified if it is to maintained, notwithstanding our view that the two means of mitigation should be integrated under a single approach, allied to the provisions of ISPA3.
Object
Documents for Download
Representation ID: 26117
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.