ipswich.gov.uk
Habitats Regulations Assessment of the Ipswich Borough Council Local Plan at Final Draft Stage (Sept 2019)
Support
Supporting Documents and PDFs for Download
Representation ID: 26287
Received: 25/02/2020
Respondent: Natural England
Agent: Natural England
We are satisfied that the Habitats Regulations Assessment has provided a robust assessment of the Ipswich Local Plan final draft, in accordance with the requirements of the Conservation of Habitats and Species Regulations 2017 (as amended) and having regard to relevant caselaw. We are pleased that the recommendations for the strengthening of policy wording in the HRA screening report have been incorporated within the final draft of the Core Strategy, and issues carried forward into the Appropriate Assessment stage as we would expect, with recommendations for appropriate mitigation.
N/A
Object
Supporting Documents and PDFs for Download
Representation ID: 26346
Received: 02/03/2020
Respondent: Save Our Country Spaces
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Heathrow decision highly material. Needs referencing and assessment regarding Local Plans, Strategic Planning and Local decision making. New case law could make Local Plans, where Paris Agreement on climate change isn’t adequately taken into account or doesn’t demonstrate conformity to within HRA challengeable and potentially unlawful. Extract from judgement included. Fails to take into account non-compliance of the AQAP with Government guidelines, non-compliance of the AQA for the IGS with DM3 and train and shipping emissions, especially as shipping will clearly impact on the Orwell Estuary, which is part of a Special Protection
Area (SPA) and Ramsar site.
Not specified
Object
Supporting Documents and PDFs for Download
Representation ID: 26376
Received: 02/03/2020
Respondent: Save Our Country Spaces
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
HRA simply assumes that CS fully implemented and full funding for all measures secured. No evidence that IBC can deliver improvements in walking, cycling and bus infrastructure, improved road infrastructure and unprecedented levels of modal shift. IBC and SCC’s record in these areas is dire. HRA incomplete and underplays key issues. Needs to fully assess air quality impacts including from rail/ sea, additional road infrastructure required, re-designation of Green Rim, alternatives to HDL (and SCDC no longer needs this to meet housing target), flood risk and new sewage infrastructure. Needs to assess robustness if unprecedented levels of modal shift underachieved.
Needs to fully assess air quality impacts including from rail/ sea, additional road infrastructure required, re-designation of Green Rim, alternatives to HDL (and SCDC no longer needs this to meet housing target), flood risk and new sewage infrastructure. Needs to assess robustness if unprecedented levels of modal shift underachieved.
Object
Supporting Documents and PDFs for Download
Representation ID: 26491
Received: 02/03/2020
Respondent: Save Our Country Spaces
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Opening comments on SA, apply to HRA.
HRA incomplete and must address impacts of:
1. Proposed re-designation of Green Rim.
2. New sewage infrastructure required for growth.
3. Required traffic infrastructure identified by traffic modelling
4. Non-compliance of IGS AQA with DM3.
5. Emissions from rail and shipping.
If no such assessments are included in the HRA then needs to explain why. IBC’s response to the recommendations in relation to Paragraph 1.29 is not acceptable. CS needs strengthening to ensure
compliance with this recommendation especially given Green Rim redesignation. Also whether lack of S106 payments for RAMs IGS sites acceptable.
Update HRA.
Object
Supporting Documents and PDFs for Download
Representation ID: 26503
Received: 02/03/2020
Respondent: Northern Fringe Protection Group
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
HRA assumes that CS fully implemented and funding for all measures. No evidence that IBC can deliver improvements in walking, cycling and bus infrastructure, improved road infrastructure and unprecedented levels of modal shift. IBC and SCC’s record in these areas is dire. HRA incomplete and underplays key issues. Needs to fully assess air quality impacts, AQAP and IGS non-compliance with DM3 including from rail/ sea, additional road infrastructure required, re-designation of Green Rim, alternatives to HDL (and SCDC no longer needs this to meet housing target), flood risk, new sewage infrastructure and robustness if unprecedented levels of modal shift underachieved.
Needs to fully assess air quality impacts, non-compliance of AQAP and IGS with DM3, including from rail/ sea, additional road infrastructure required, re-designation of Green Rim, alternatives to HDL (and SCDC no longer needs this to meet housing target), flood risk and new sewage infrastructure. Needs to assess robustness if unprecedented levels of modal shift underachieved.
Object
Supporting Documents and PDFs for Download
Representation ID: 26539
Received: 02/03/2020
Respondent: Northern Fringe Protection Group
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Opening comments on SA, apply to HRA.
HRA incomplete and must address impacts of:
1. Proposed re-designation of Green Rim.
2. New sewage infrastructure required for growth.
3. Required traffic infrastructure identified by traffic modelling
4. Non-compliance of IGS AQA with DM3.<br> 5. Emissions from rail and shipping.
If no such assessments are included in the HRA then needs to explain why. IBC’s response to the recommendations in relation to Paragraph 1.29 is not acceptable. CS needs strengthening to ensure
compliance with this recommendation especially given Green Rim redesignation. Also whether lack of S106 payments for RAMs IGS sites acceptable.
Update HRA accordingly.