Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Object

Representation ID: 26508

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

5.25; Improving air quality in the increasing number of Ipswich AQMAs (now five) needs to be added as a key challenge. IBC should be “delivering high levels of modal shift” rather than just “guiding as many trips as possible to sustainable modes” .Meeting the Climate Emergency needs to be added as a key challenge.
5.26 - table 2 - There are inconsistent references throughout the document (6.16, IBC FRA webpage, 8.45, 8.46, 8.225, DM4 PRFA). The situation regarding flood risk assessment within the CS is confusing and makes flood risk impossible to understand for the general public. Requires further clarification.

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: 26510

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Regarding northern route (paragraph 8.19), IBC states support for such a route. We would like to draw attention to the article in the Ipswich Star (27/02/2019) and East Anglian Daily Times (22/02/2020) where the leader of IBC supports a northern bypass. Both previous Labour and Conservative Ipswich MPs have also argued for a northern route as a priority. This paragraph and the CS need to be updated to take account of the decision that the northern route will NOT be progressed further.

Object

Representation ID: 26511

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

IBC must explain why elected leader believes Ipswich cannot cope with existing volumes of traffic and that it's sound to increase traffic. Needs to recognise that SCC is concerned about traffic volume management and announced that it's establishing a taskforce to look at new ways of tackling the town's traffic. See David Ellesmere quote re; Europa Way/ Bramford Road link. TUOC and Northern Route not proceeding. Substantial evidence of modal shift delivery and funding needed to demonstrate this achievable. ISPA modelling needs to include additional highway schemes (see list). Ambiguity over delivery dates and funding. Detailed comments on mitigation strategy.

Object

Representation ID: 26512

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Challenge need for future development at the northern end of Humber Doucy Lane. This is no longer required by Suffolk Coastal to meet its housing target. Settlement Sensitivity Assessment recognises the sensitivity of the open land between the edge of suburban Ipswich and villages of Westerfield and Rushmere. Concludes that the area is “sensitive to development” and “care will be needed to ensure rural countryside beyond the Ipswich administration area continues to function as a green rim to the town". Site too important/ sensitive to be built on, especially as it will need additional primary school, which has traffic implications.

Object

Representation ID: 26513

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We do not believe that the full proposed expansion of the town centre retail development is required or sustainable and that this land could be better used for new homes. Question the need to allocate part of the Westgate site and the Mint Quarter for retail. We have always argued that Ipswich Borough Council has been over-estimating retail demand (as with previous undeliverable homes and employment targets).

Object

Representation ID: 26514

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Level of town centre retail development isn't required , land better used for new homes. Town centre housing has lower impact on traffic congestion and air quality than outskirt development. Opportunities to convert existing excess town centre retail into housing. This approach should be used instead of Humber Doucy Lane, which will exacerbate traffic congestion into town centre and along Valley/Rd/Colchester Rd. Ipswich Central supports increase in town centre homes. Will improve town centre and night-time economy, reduce traffic into the centre, facilitate modal shift and improve air quality. Parking Strategy over-estimates parking demand, brownfield parking land better for housing.

Object

Representation ID: 26516

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Traffic will increase traffic at junctions that are already over-capacity without any additional infrastructure. Breach of CS16 regarding protection/ enhancement of green corridors and the Green Rim (regardless of it being designated as countryside). Breach of policies DM8, DM10 and DM11 as no net biodiversity gains or green infrastructure though development. Acts as a rural buffer. Regardless, should be no development of this land until completion of IGS. Needs to be clarified in the CS. SA needs to fully assess implications on building on site and whether delivering more homes in town centre instead of retail is more sustainable option.

Object

Representation ID: 26517

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Strongly disagree with the proposed change to replace “green rim” with “green trail”. The existing green rim is an asset and should be protected by adding it to Policy CS4, especially as Ipswich Borough Council have previously massively reduced its size and are now attempting to
reclassify it and hence destroy it. Change in name is misleading and is actually to bring forward land at Humber Doucy Lane for development. Non-compliant with DM8. See appendix 1 for history of the green rim/ corridors. No mention of the green rim/ trail being used in the Ipswich Cycling Strategy.

Object

Representation ID: 26518

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Existing green rim is an asset and should be protected by adding it to CS4, especially as IBC have previously massively reduced its size and are now attempting to reclassify it and destroy it. Not clear what RAMS S106 payments agreed with CBRE and Crest sites as S106 are not publicly available. If no RAMS tariffs included in the S106 agreements this could be in breach of this SPD and policies CS4, CS17 and Policy DM31 of the adopted CS. New CS would be unsound in relation to CS4 CS17 and DM 8 as no means of funding the required.