Post Submission Main Modifications Core Strategy and Policies (DPD) and Site Allocations and Policies (incorporating IP-One Area Action Plan) (DPD)

Object

Representation ID: 24417

Received: 01/12/2016

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? Not specified

Modifications fail to address major issues: the adverse impact of the Local Plan on traffic congestion and air quality (described today by NICE as a Public Health "Crisis"), which is a risk of allocating all IGS for "multi-start" development without adequate safeguards on phasing. This presents an unacceptable Health Impact risk which may be deemed unlawful. Drainage and lack of sewage infrastructure have not been addressed. Public Health Impacts from development across the town need monitoring and assessment. During the Inquiry, IBC agreed to incorporate a Public Health Adverse Impact Study requirement, yet no requirement is referenced within the modifications. SOCS endorses the NFPG representation also.

Object

Representation ID: 24429

Received: 01/12/2016

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? Not specified

As the purpose of "Sustainable Development" should be delivery of Public Health, Well Being and Environmental protection, the Climate Change agenda and Act should be fundamental considerations. Object to the removal of "Climate Change" and "a-j" from CS1 (viability considerations should not be the deciding factor). Modified supporting text weakens the plan. Deference to the NPPF is misplaced. Oppose the suggestion that the NPPF "guidance" amounts to a "balancing act" between Public Health, environmental protection and growth. Relegating assessment of impacts to DM policies may result in poor decision making. 8.20 Climate Change may not be adequately addressed through CS18.

Object

Representation ID: 24433

Received: 01/12/2016

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? Not specified

We object to the removal of the "Green Rim" in MM36 as it will weaken this policy and will weaken protection of the countryside from inappropriate development. Removal of this text compromises and weakens MM16 [policy CS16] as it may add to existing long term open space deficits and reduce effectiveness of local biodiversity and ecological networks outlined in MM21 [policy DM3]. Green rim should be considered an impediment to development. SOCS feel text is contradictory and does not support the new text - the green rim relating to ecological corridors at the end of this section of new text.

Object

Representation ID: 24434

Received: 01/12/2016

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? Not specified

See comments on the issue of viability determining policy- text modification -SOCS say this is unacceptable on Public Health risk grounds. 9.49 proper account of the designated heritage assets of Red House must be taken and not be overlooked
in the "balancing act" and taken into account for NPPF 133 and 134.

Object

Representation ID: 24435

Received: 01/12/2016

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? Not specified

The sensitive of Red House and adjacent scheduled monument site must be properly
taken into account in IGS decisions.

Object

Representation ID: 24436

Received: 01/12/2016

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? Not specified

MM 27 (DM 17) object to the subjective text in
a. "..not result in severe adverse impacts" and
b. "not result in significant impacts on air quality or AQMA" ,
as it does not afford sufficient public protection and will conflict with NICE issued guidance to Local Authorities and planners.
SOCS endorses the NFPG representation also.

Object

Representation ID: 24437

Received: 01/12/2016

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? Not specified

MM37 Object to changes in DM34 suggesting " flexibility in relation to development in the countryside" as it may compromise County Wildlife sites like the Fynn Valley on NW Ipswich Fringe and the NW villages in Suffolk Coastal.
Strongly object to removal of b. protecting agricultural land.
9.211 Object to (new paragraph), 'Subject to infrastructure and highways constraints, there are some areas of countryside within the Borough Boundary which have been assessed as having "in principle" acceptance for housing through the SHLAA... etc..' These sites have NOT been assessed in the SA.

Object

Representation ID: 24438

Received: 01/12/2016

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? Not specified

MM 38 Chapter 10, table 8B Object to removal of strategic phasing plans. SOCS endorses the NFPG representation also.

Object

Representation ID: 24439

Received: 01/12/2016

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? Not specified

Objective 11: SOCS cannot see how this can be delivered. Targets on Air Quality likewise. The modifications outline here mitigate against this being achieved. Please note references to Air Pollution impacts locally and recent court decisions and guidance issued by NICE.
1. NATIONAL INSTITUTE FOR HEALTH AND CARE EXCELLENCE Guideline scope Air pollution: outdoor air quality and health Topic.
2. ClientEarth wins air pollution case in High Court 2 November 2016.
3. Charles Croydon, local St Margaret's ward resident.
4. Calls for more monitoring sites in Kesgrave for air pollution November 2016.
SOCS endorses NFPG representation also.

Object

Representation ID: 24440

Received: 01/12/2016

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? Not specified

SOCS view is very much aligned with North Fringe Protection Group (NFPG) detailed response. SOCS sign up to the NFPG submission attached as Appendix A.
Part B for CSR MM5, MM6, MM9, MM10, MM18, and MM27
SOCS specific additional concerns relate to: CSR MM1, MM2, MM4, MM16, MM17, MM22, MM24, MM25, MM36, MM37,MM38, in MM39-Objective 11, MM44-Policy maps.
IBC comment: specific objections have been entered against all these modifications except MM2, MM4, MM16, MM25 and MM44, which are logged as general objections.