Strategic Environmental Assessment and Sustainability Appraisal - Proposed Submission Core Strategy and Policies DPD

Object

Representation ID: 5594

Received: 05/03/2015

Respondent: Save Our Country Spaces

Legally compliant? No

Sound? No

Duty to co-operate? No

Likely predicted Climatic Change and adverse climatic weather impacts are insufficiently addressed with insufficient work on Compound and Cumulative Impacts likely, especially from the Suffolk Coastal District growth and expansion plans. A Joint Environmental Impact Assessment of the Core Strategy is needed for the whole of the Ipswich Policy Area. An isolated EIA on the Northern Fringe would provide no necessary safeguards for public health. Hyder's SA does not address the issues we suggest. (see Appendix E [of full submission] - SOCS 2 Sept 2014 SA Scoping Update Consultation).

Object

Representation ID: 5597

Received: 05/03/2015

Respondent: Save Our Country Spaces

Legally compliant? No

Sound? No

Duty to co-operate? No

SA is not fit for purpose. The adopted CS allows a phased approach to development of the Northern Fringe/IGS and its SA judged multiple starts as unsustainable. The revised CS now allows multi-site development across the NF. A detailed examination of the implications must be included in the new SA and a full critique of the rationale behind the proposed changes. With multiple starts, if one developer hits financial problems, the added burden on remaining developers may make their operation unviable and halt delivery. This would blight the land. What contingency is there if market forces impact on infrastructure delivery?

Object

Representation ID: 5609

Received: 05/03/2015

Respondent: Save Our Country Spaces

Legally compliant? No

Sound? No

Duty to co-operate? No

SOCS commented previously (September 2014) in response to IBC's updated SA scoping consultation letter. SOCS feel the responses given to key issues in the letter sent do not address these key issues [the need to incorporate an updated evidence base and give more detailed consideration to alternative spatial options] sufficiently. SOCS reserve the right to continue to question the "evidence base".

Object

Representation ID: 5610

Received: 05/03/2015

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Regarding Air Quality and air Pollution impacts, the SA is totally lacking in capacity to reflect the current situation regarding lack of resource; eg lack of data and continuous monitoring within Ipswich from traffic, lack of particulate impacts; lack of progress in responding to emerging health impacts from Air pollution; lack of work and remit within the SA for Cumulative and compound impacts for Ipswich from multiple sources of air pollution ie Industrial, biomass, clinical and traffic and also from the crematorium. Also from "chem trails" from overhead aircraft. All in combination from impacts from Europe impacting Ipswich adversely.

Object

Representation ID: 5611

Received: 05/03/2015

Respondent: Save Our Country Spaces

Legally compliant? No

Sound? No

Duty to co-operate? No

SOCS argued [previously] that IBC's Core Strategy was unsustainable as it was based on unrealistic job targets. The previous SA failed to recognise these concerns. Evidence now shows that the jobs target was unsustainable and the original SA incorrectly assessed the CS as sustainable. A more evidence-based approach to SA is required. We are disappointed that IBC has ditched the employment-led strategy in favour of a housing-led approach. There has been no assessment or evidence of the relative merits of such an approach compared to a realistic jobs-led strategy. The SA needs to consider the implications of this key change.

Object

Representation ID: 5612

Received: 05/03/2015

Respondent: Save Our Country Spaces

Legally compliant? No

Sound? No

Duty to co-operate? No

The full sustainability implications of the change in the focus of the CS on the wider transport network must also be fully assessed in the new SA. This can only be completed through detailed traffic assessment and modelling on an integrated basis across Ipswich Borough and in neighbouring authorities that takes full account of relevant employment sites and proposed new housing developments. This needs to assess the impact on air pollution as traffic from the NF will pass through AQMAs and areas of pollution concern as residents travel to work. This approach is required under the Duty to Co-operate.

Object

Representation ID: 5613

Received: 05/03/2015

Respondent: Save Our Country Spaces

Legally compliant? No

Sound? No

Duty to co-operate? No

The adopted CS allows for a phased approach to development of the NF. Its SA judged multiple starts as unsustainable. However, the revised CS now allows simultaneous multi-site development across the NF without locational restrictions. A detailed examination of the implications of this change must be included in the new SA and a full critique of the rationale. Multiple starts may pose the risk that if a developer/landowner hits financial problems, the added burden [of infrastructure provision] falls on remaining landowners/developers, making their operation unviable and halting delivery, resulting in blight. Grampian Conditions are not mentioned within the Scoping report.

Object

Representation ID: 5725

Received: 05/03/2015

Respondent: Save Our Country Spaces

Legally compliant? No

Sound? No

Duty to co-operate? No

SOCS endorse the Northern Fringe Protection Group's points. We want the best for Ipswich with the right policies put in place to deliver successful outcomes. This can only be achieved if the SA accurately identifies the many issues facing Ipswich, which are highly visible and recognised by its residents. As in our previous consultations responses, we maintain that the SA fails to accurately reflect the state of Ipswich and presents a very optimistic view of the impacts of the CS on the Borough.

Object

Representation ID: 5726

Received: 05/03/2015

Respondent: Save Our Country Spaces

Legally compliant? No

Sound? No

Duty to co-operate? No

SOCS endorse the Northern Fringe Protection Group's points. Concerned that previous comments on Table 3-2 and Table 3-3 have been ignored.

Object

Representation ID: 5727

Received: 05/03/2015

Respondent: Save Our Country Spaces

Legally compliant? No

Sound? No

Duty to co-operate? No

Endorse NFPG points. Pleased that the SA recommends updated traffic modelling. The SA does not adequately consider the effects of multiple starts from the Garden Suburb, the outputs of Suffolk County Council feasibility work into solutions for the road network around the Garden Suburb, the views of the highway authority that sustainable transport measures have not been adequately identified in the current planning application, congestion and capacity issues, the conclusions of the transport assessment and resulting air quality impacts submitted with the CBRE application, decreasing air quality, legally binding air quality limits and effects of poor air quality on cycling/walking.