Object

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.

Object

Representation ID: 26374

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Assumes that CS fully implemented and full funding for all measures. No evidence delivery of improvements in walking, cycling and bus infrastructure, improved road infrastructure and unprecedented levels of modal shift. IBC and SCC’s record regarding this is dire. HIA 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, climate change declaration, 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: 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.

Object

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.