Final Draft Ipswich Local Plan 2018 - 2036 Sustainability Appraisal Report (SEA and SA)

Object

Representation ID: 26341

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Appears that environmental, social and economic effects of plan(s) are inadequately/ inaccurately
assessed against HRA and the SA. The SEA Directive requires that assessment include identification of cumulative and synergistic effects, including other neighbouring local authorities. The SA does not appear to take account of the cumulative effect of CSs Plans of neighbouring authorities with regard to housing, employment and especially transport/traffic and increased air pollution and traffic congestion. Needs to fully assess the implications on building on HDL and whether delivering more homes in the town centre instead of retail expansion might be a more sustainable option.

Object

Representation ID: 26345

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Highly material is the decision/ judgement released from The Supreme Court on Climate Change and development- (Heathrow)1. This needs referencing and being taken into account within Local Plans as it is a fundamental game changer with respect to Local Plans, Strategic Planning and Local Development Control and Planning Committee decision making. This new case law could make Local Plans, where Paris Agreement on climate change, (concluded in December 2015 and ratified by the United Kingdom in November 2016) isn’t adequately taken into account or doesn’t demonstrate conformity to within Strategic Environmental Assessment challengeable and potentially unlawful. Extract from judgement included.

Object

Representation ID: 26373

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

SA 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. SA 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.

Object

Representation ID: 26377

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The housing requirement in Suffolk Coastal has been reduced by the Planning Inspector from 582 homes pa (10,476) 2018-2036 to 542 pa (9,756). Suffolk Coastal no longer needs the land at Humber Doucy Lane to provide the 150 homes (to be built after 2031) it had included in its final draft plan10 (paragraph 12.209). The SA fails to assess this and is unsound.

Object

Representation ID: 26378

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The proposal to allow development in north-east Ipswich at the northern end of Humber Doucy Lane and Tuddenham Road is not justified and therefore unsound. Land in the centre of Ipswich earmarked for expanded retail and car parking (which we believe is surplus to requirements), should be used for new homes instead. There is no SA of this viable alternative.

Object

Representation ID: 26485

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

No SA of:
- Lack of sewage infrastructure for IGS and ISPA and environmental impacts of new sewage infrastructure (emissions and traffic congestion)
- air quality or noise assessment in relation to rail transport (Ipswich Chord and Freight yard) and additional freight to/ from Port of Felixstowe,
- environmental impacts of Port of Ipswich.
- potential impacts of increased freight traffic on IGS pedestrian bridge and Westerfield rail crossing
- decision to destroy Green Rim by building homes on ISPA4 and re-designating as Green Trails.
- lack of full appraisal of the impacts on building ISPA4.
- omitting Climate-Emergency Declaration