Support

Representation ID: 26177

Received: 05/02/2020

Respondent: Suffolk Constabulary

Suffolk Constabulary does not have any further comments to make relating to the soundness or legal compliance of this document. May I take this opportunity to acknowledge the positive enhancements to the local plan in terms of the adherence with security measures. Partnership working in this way will ensure that all opportunities to design out crime are taken at the earliest stage in the process, helping to keep our communities safer and providing homeowners and businesses with a clear framework within which to operate.

Support

Representation ID: 26200

Received: 14/02/2020

Respondent: National Grid

Agent: Avison Young

We have reviewed the document and can confirm that National Grid has no comments to make in response to this consultation.

Object

Representation ID: 26205

Received: 21/02/2020

Respondent: Ipswich & East Suffolk Clinical Commissioning Group & West Suffolk CCG

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

IBC healthcare provision equals 13 GP's, 2 branch surgeries, 36 pharmacists, 26 dental surgeries, 20 opticians, 1 Acute hospital and 6 clinics. The CCG, Local Authorities and local stakeholders has started addressing Primary Care capacity issues. These projects will deliver additional capacity to meet previously identified growth. Upon review some existing health infrastructure will require further investment/ improvement to meet the needs of growth in this LP. Growth would have an impact on healthcare provision which, if unmitigated, may not be sustainable. Provision needed to address development impact on health infrastructure and ensure timely cost-effective delivery of necessary infrastructure improvements.

Support

Representation ID: 26228

Received: 21/02/2020

Respondent: Ipswich & East Suffolk Clinical Commissioning Group & West Suffolk CCG

Objective 10 - The CCG is undergoing a data gathering exercise for all primary care facilities in Suffolk with the aim of providing a 6-facet survey. The outcome of this project will be reliable data showing the CCG the general physical condition of all primary care facilities. Once this information is known the CCG will be in a better position to know which facilities require improvement and which facilities are in good condition.

Object

Representation ID: 26274

Received: 28/02/2020

Respondent: Environment Agency

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Paragraph 6.16 states that the Strategic Flood Risk Assessment (SFRA) has been revised. However, this is currently being updated so this section should be amended. The Local Plan should also refer to the SFRA as being a living document.

Support

Representation ID: 26289

Received: 25/02/2020

Respondent: Natural England

Agent: Natural England

Natural England is satisfied that our recommendations at earlier stages in the Local Plan process have been taken into account within the Ipswich Local Plan final draft. Natural England considers the approach taken with regards to the natural environment to be sound (in accordance with our remit) within the Ipswich Local Plan final draft.

Object

Representation ID: 26316

Received: 02/03/2020

Respondent: Suffolk Wildlife Trust

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

“9. NATURAL ENVIRONMENT – To protect and enhance high quality, accessible strategic and local open spaces rich in biodiversity and geodiversity for people to visit and use.“ Consider addition of reference to ecological networks and connectivity. NPPF references the need to establish, conserve, restore and enhance ecological networks under Paragraphs 173-d. and 174-b.

Object

Representation ID: 26340

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Issues raised need to be fully assessed/ addressed for LP to be ‘sound’. LP is unsound and doesn't comply with NPPF. “Climate Change” agenda insufficiently addressed. Proposals contrary to; NPPF 10. Environmental, social and economic effects of the plan(s) are inadequately/ inaccurately assessed against HRA and SA. “Serious adverse effects” not properly identified, as required under NPPF. This means any planning application almost impossible to determine, rendering the major IGS applications problematic and renders stakeholder responses to applications a problem. NPPF-11 not considered. Employment/ homes growth, including IGS, undermined by ongoing failure to properly assess cumulative requirement for wastewater infrastructure.

Object

Representation ID: 26342

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Growth, must be measured against the potential for serious adverse effects and serious adverse impacts, including Quality of Life and Public Health. Potential to secure a “sustainable future” for existing local population, future populations/ generations is not demonstrated. Specific issues to be addressed:
1. Drainage
2. Flooding (Westerfield)
3. Sewage capacity
4. Traffic impact
5. Air pollution and health impact
6. Pressures on local facilities
7. Road widening/ removal of vegetation/ verges
8. Loss of high grade agricultural land
9. Loss of trees/ habitats
10. Country park delivery stalling
11. No need for dwellings given lack of new local jobs.

Object

Representation ID: 26348

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Lack of realistic accounting for the adopted policy on Climate Emergency and the Climate Change agenda, for 10 of the 12 objectives. Specifically in relation to traffic related issues, including delivering the required infrastructure and modal shift and the associated impact on air quality; climate emergency and climate change precipitated flood risk, loss of grade 2 farm land, loss of vital green rim and urban/rural separation with its attendant adverse impacts on the network of wildlife links with green corridors, especially to the County Wildlife site area of the Fynn Valley.

Object

Representation ID: 26359

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Objective1; inadequately demonstrated. Objective 2; the 4% and 5% affordable housing negotiated on IGS doesn't match with the 31% quoted. Evidence of recent job losses in town undermines credibility of job target. Objective 3; Lack of justification for HDL. Objective 5; Concerns about railway noise/ vibration from intensification of line and traffic from humpback bridge. Current rail noise causes residents complaints and audible for a distance of about 1/4-1/2 a mile at night causing significant sleep-disturbance especially in summer. 5 point rail plan agreed 2018 and no assessment of diesel pollution. Adopted indicator of air quality exceedances should be reinstated.

Object

Representation ID: 26362

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Objective 6:
1. Junctions/ link roads at/near capacity, not addressed. No evidence growth is sound.
2. Severe capacity issues in 2026 but no infrastructure projects in Infrastructure Tables. Especially town centre, Ipswich Garden Suburb and A1214.
3.Modelling fails to identify when junctions will reach capacity.
4. Failing to Improve Access in breach of CS5. Modal Shift assumptions too high, uncompliant with CS20.
5. CCC assumes 10% modal shift by 2050. No evidence 15% modal shift deliverable by 2026? CCC assumption should be used.
6. Existing walking/ cycling infrastructure substandard, won't enable delivery of modal shift. Need new cycling indicator.

Object

Representation ID: 26363

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Objective 6 (continued)
7. No funding allocated in IBC’s financial plan to encourage modal shift.
8. Doesn't include proportionate evidence. New Evidence database incomplete as excludes Transport documents, especially modal shift related and S106 schedules for approved IGS developments which haven't been made publicly available.
9. Concerned that road bridges (and country park) may not be delivered in time (February 2022) to receive £9.8m HIF. If so, then CS is unsound unless alternative funding available.
10. Not positively prepared as fails to fully assess transport infrastructure requirements, especially in relation to timing of delivery (including sewage).

Object

Representation ID: 26367

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Objective 5:
1. Inconsistent with national policy, fails to comply with legal limits. Must be requirement.
2. Strengthen commitment to Improve Air Quality, no real improvement over past decade.
3. No funding in IBC’s financial plan for improving air quality.
4.No AQA. Must be completed urgently. Include assessments for early years of developments, construction-related traffic and rail/sea traffic and impacts of different levels of modal shift rather than unsubstantiated levels assumed.
5. Little point undertaking an AQA in 2036 as ban on non-electric vehicles. Early years likely to be worst. Suggest earlier assessment.
6. Ambiguity over 2004 emission levels cited.

Object

Representation ID: 26370

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Objectives 4 and 9; At the Executive meeting 9th July 2019 Ipswich Borough Council Declared a Climate Emergency. The CS needs to be updated to incorporate this to be sound.

Object

Representation ID: 26380

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Specific Objectives are required to ensure delivery of key aspects of the CS such as improving transport infrastructure, improving air quality, delivering modal shift and improving accessibility are required. These need to be monitored and reported on to ensure the CS is effective. The Vision needs to include an improvement in air quality levels and compliance with legally binding
targets. Climate emergency also needs to be included.

Object

Representation ID: 26383

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Objective 6; why 15% modal shift by 2031 target removed given still required for soundness. Imperative that modal shift target for 2026 included. Must report the modal shift levels achieved through Travel Ipswich in AMR (appendix 5 quoted). Evidence needed showing that modal shift can be delivered. Need to illustrate what "additional east-west highway capacity" is. Considerable investment in public transport required. Insufficient firm proposals or funding to deliver the required modal shift levels throughout the CS period. CS is unsound as it lacks a transport solution that supports proposed growth. Switch to electric cars will not solve health impacts.

Object

Representation ID: 26438

Received: 02/03/2020

Respondent: Kesgrave Covenant Ltd

Agent: Kesgrave Covenant Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Whilst strongly support residential allocation for land at Humber Doucy Lane, seeking relatively minor amendments to detailed wording which is considered neither justified nor effective and therefore not sound. This will ensure no unnecessary delays to delivery of development. As currently written, the Plan identifies the land for "future" development and states that it will be "appropriately phased" with Garden Suburb and associated infrastructure. Amend to provide greater clarity regarding required infrastructure. Plan should not make generic references to "future" development or refer to requirement for phasing without appropriate evidence/details. Wording of paragraph 6.17 should be amended to reflect this.

Object

Representation ID: 26493

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Objective 6:
1. Junctions/ link roads at/near capacity, not addressed. No evidence growth is sound.
2. Severe capacity issues in 2026 but no infrastructure projects in Infrastructure Tables. Especially town centre, Ipswich Garden Suburb and A1214.
3.Modelling fails to identify when junctions will reach capacity.
4. Failing to Improve Access in breach of CS5. Modal Shift assumptions too high, uncompliant with CS20.
5. CCC assumes 10% modal shift by 2050. No evidence 15% modal shift deliverable by 2026? CCC assumption should be used.
6. Existing walking/ cycling infrastructure substandard, won't enable delivery of modal shift. Need new cycling indicator.

Object

Representation ID: 26496

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Objective 6 (continued)
7. No funding allocated in IBC’s financial plan to encourage modal shift.
8. Doesn't include proportionate evidence. New Evidence database incomplete as excludes Transport documents, especially modal shift related and S106 schedules for approved IGS developments which haven't been made publicly available.
9. Concerned that road bridges (and country park) may not be delivered in time (February 2022) to receive £9.8m HIF. If so, then CS is unsound unless alternative funding available.
10. Not positively prepared as fails to fully assess transport infrastructure requirements, especially in relation to timing of delivery (including sewage).

Object

Representation ID: 26497

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Objective 5:
- Inconsistent with national policy, fails to comply with legal limits. Must be requirement.
- Strengthen commitment to Improve Air Quality, no real improvement over past decade.
- No funding in financial plan for improving air quality.
- No AQA. Must be completed urgently. Include assessments for early years of developments, construction traffic, rail/sea and different levels of modal shift rather than unsubstantiated levels assumed.
- Pointless undertaking an AQA in 2036, banned non-electric vehicles. Early years worst. Suggest earlier assessment.
- Ambiguity over 2004 emission levels cited.
- Object to removal of 'improve Air Quality' objective/ indicator.

Object

Representation ID: 26498

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Objectives 4 and 9; At the Executive meeting 9th July 2019 Ipswich Borough Council Declared a Climate Emergency. The CS needs to be updated to incorporate this to be sound.

Object

Representation ID: 26507

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Specific Objectives are required to ensure delivery of key aspects of the CS such as improving transport infrastructure, improving air quality, delivering modal shift and improving accessibility are required. These need to be monitored and reported on to ensure the CS is effective. The Vision needs to include an improvement in air quality levels and compliance with legally binding
targets. Climate emergency also needs to be included.

Object

Representation ID: 26509

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Objective 6; why 15% modal shift by 2031 target removed given still required for soundness. Imperative that modal shift target for 2026 included. Must report the modal shift levels achieved through Travel Ipswich in AMR (appendix 5 quoted). Evidence needed showing that modal shift can be delivered. Need to illustrate what "additional east-west highway capacity" is. Considerable investment in public transport required. Insufficient firm proposals or funding to deliver the required modal shift levels throughout the CS period. CS is unsound as it lacks a transport solution that supports proposed growth. Agree some form of northern route required for soundness.

Object

Representation ID: 26534

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The effectiveness of the CS to deliver both employment and homes growth including the IGS could be seriously undermined by the ongoing failure to properly assess the cumulative requirement of Ipswich for wastewater infrastructure over the CS period and plan for its provision. This remains a major failing of the CS making it unsound. We note that improvements to sewage infrastructure has been included in ISPA2 and it also needs to be included in relation to the IGS. The potential impact of Sizewell C on the IGS and the CS has not been assessed in any form of sensitivity analysis.

Object

Representation ID: 26552

Received: 02/03/2020

Respondent: Cardinal Lofts (Mill) Ltd

Agent: Cardinal Lofts (Mill) Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Company continues to support the general Vision as is set out at paragraph 6.7. It is also in general agreement with the Objectives (paragraph 6.8), but considers that there should be explicit recognition
that, unless development is viable (or is subsidised from the public purse) it will not take place and the Vision will not, therefore, be achieved (and is unsound). Object for the reasons set out above. The inclusion of the word ‘viable’ needs to be added to Objective 4.

Support

Representation ID: 26553

Received: 02/03/2020

Respondent: Cardinal Lofts (Mill) Ltd

Agent: Cardinal Lofts (Mill) Ltd

The Company offers its general support for the spatial strategy, as set out at paragraphs 6.10 to 6.22, and, in particular, the objective of focusing development in central Ipswich in order to tackle issues of deprivation and social exclusion (see also paragraph 6.8 - Objective 3). Summary: Support.

Object

Representation ID: 26611

Received: 02/03/2020

Respondent: Councillor Oliver Holmes

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

To be sound, reference needs to be made to the Government’s net zero 2050 policy together with reference to IBC’s Climate Emergency Declaration July 2019. This needs to be an overarching policy vision over the whole of the Core Strategy. Failure to do so could make the CS unlawful.

Object

Representation ID: 26613

Received: 02/03/2020

Respondent: Councillor Oliver Holmes

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Development in itself is unlikely to achieve any reduction in carbon emissions. Objective should be re-written so that permitted development will not add to carbon emissions. To be sound, reference should be made to air quality/pollution and the need for development not to increase poor air quality in existing and potentially new Air Quality Management Areas. Throughout Plan, references made to significant modal shift to achieve sustainability. However, although this has existed for some years, there is no evidence of modal shift. Continued reference to such shift could be seen as disingenuous. Objective needs to provide initiatives/disincentives to developers.

Object

Representation ID: 26617

Received: 02/03/2020

Respondent: Councillor Oliver Holmes

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Any development in Humber Doucy Lane must not take place until the Garden Suburb is substantially completed. “Appropriately phased” is too open-ended. To be sound, and to enable completion of the Garden Suburb, no development should occur before a trigger point of 3,200 completed homes.