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

Object

Representation ID: 26530

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Transport Modelling includes challenging modal shift assumptions. Unless evidence of funding and plans to improve the ineffective cycling network provided, the levels of modal shift unreachable. Contrary to NPPF 181. CS needs to make clear commitment to improving air quality and compliance with legally binding air pollution targets. Fails to follow Government’s guidelines and waters down Government requirements. Flaws in WSP Source Apportionment Study. New modelling needs to address issues and focus on air quality in first 10 years. No AQA provided as part of this consultation, unacceptable. Reserve right to comment on this. No AQA for IGS.

Object

Representation ID: 26531

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Only two major changes to cycle network since adopted CS. Lack of commitment to maintain existing network and cycle infrastructure poor. Need to evidence initiatives implemented and modal shift achieved. No progress in meeting requirements of CS5. SCC draft local cycling & walking infrastructure plan referenced. Clear that without major improvements there is no chance of modal shift being achieved. Cycling/ walking is unattractive, unsafe, incoherent and uncomfortable. Bus routes just go into town rather than radial. Investment in bus network required. No money allocated over four-year period to improving air quality, delivering modal shift or improving cycle/ pedestrian infrastructure.

Object

Representation ID: 26532

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Concerns on road network to cope with additional traffic without northern relief road. Concerned bridges not built in time (March 2022) to secure HIF and permissions only require vehicle bridge on delivery of 699 homes, impossible before March 2022 (HIF). Bridge too narrow for all road users and needed for safety. Without early delivery of road/ pedestrian bridge, no safe walking/cycling. Need contingency measures for alternative funding and evidence that infrastructure deliverable. Delivery of roads must be compatible with traffic modelling. Unless alternative funding provided, levels of modal shift will not be achieved by 2026.

Object

Representation ID: 26533

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Concerns about funding of off-site infrastructure due to late trigger point in permissions, undermining modal shift 2026 delivery. Modelling is hiding fact that Ipswich roads near IGS are already heavily congested with roads already operating at capacity at peak times. Modelling must identify when key junctions and links reach capacity and how congestion will be mitigated. Concerned that modelling work shows greater than 100% capacity in both 2026 and 2036 on small residential roads, worsening air quality and no assessment of this factored in. Sizewell-C and Felixstowe 30% increase in trains not assessed (rail-freight). No AQA for IGS permissions. Unsound.

Object

Representation ID: 26534

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The effectiveness of the CS to deliver both employment and homes growth including the IGS could be seriously undermined by the ongoing failure to properly assess the cumulative requirement of Ipswich for wastewater infrastructure over the CS period and plan for its provision. This remains a major failing of the CS making it unsound. We note that improvements to sewage infrastructure has been included in ISPA2 and it also needs to be included in relation to the IGS. The potential impact of Sizewell C on the IGS and the CS has not been assessed in any form of sensitivity analysis.

Object

Representation ID: 26536

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

No firm proposals for new sewage infrastructure required for the IGS and the wider Ipswich area, which need to be consulted upon and included in the Infrastructure Tables. The 13 transport projects need to be included in the Infrastructure Tables. If any of projects aren't delivered by the required dates (which need to be identified) then the traffic modelling will be flawed as traffic flows will not have been properly assessed and the CS unsound. Evidence needed showing funding is in place for these schemes compatible with required delivery dates. Bramford Road/ Sproughton Road link road must be included.

Support

Representation ID: 26537

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

We support the new Policy 20 as a pragmatic and sensible response to an increasing issue in Ipswich.

Object

Representation ID: 26538

Received: 02/03/2020

Respondent: Northern Fringe Protection Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Object to removal crtierion a. Specifically; “rights of way or the local road network in respect of traffic capacity” must be reinstated as walking/ cycling shouldn't be reduced as traffic congestion is a major problem and local new developments shouldn't negatively impact. Changes conflict with CS5. Support change regarding highway safety (criterion B). However IGS is non-compliant as failed to assess impacts of development on air quality. Revised assessment of air quality impacts of IGS urgently required before commencement. Unclear how ‘severe’ and ‘significant’ impacts defined. Maximum legal limits for particulates and nitrous oxides, and this should be ‘significant’.