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

Object

Representation ID: 26340

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Issues raised need to be fully assessed/ addressed for LP to be ‘sound’. LP is unsound and doesn't comply with NPPF. “Climate Change” agenda insufficiently addressed. Proposals contrary to; NPPF 10. Environmental, social and economic effects of the plan(s) are inadequately/ inaccurately assessed against HRA and SA. “Serious adverse effects” not properly identified, as required under NPPF. This means any planning application almost impossible to determine, rendering the major IGS applications problematic and renders stakeholder responses to applications a problem. NPPF-11 not considered. Employment/ homes growth, including IGS, undermined by ongoing failure to properly assess cumulative requirement for wastewater infrastructure.

Object

Representation ID: 26342

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Growth, must be measured against the potential for serious adverse effects and serious adverse impacts, including Quality of Life and Public Health. Potential to secure a “sustainable future” for existing local population, future populations/ generations is not demonstrated. Specific issues to be addressed:
1. Drainage
2. Flooding (Westerfield)
3. Sewage capacity
4. Traffic impact
5. Air pollution and health impact
6. Pressures on local facilities
7. Road widening/ removal of vegetation/ verges
8. Loss of high grade agricultural land
9. Loss of trees/ habitats
10. Country park delivery stalling
11. No need for dwellings given lack of new local jobs.

Object

Representation ID: 26343

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Comments prepared in liaison with NFPG. SOCS have consistently baulked at the unrealistic/ unjustified housing and job targets. We have challenged population projections which have driven this agenda. Good, at last, that the legacy of growth, expansion, over ambition and wishful thinking of the early 2000’s finally are being challenged. However, there is a way to go to
achieve a sound plan. The Duty to Cooperate is hard for Ipswich to achieve when partner organisations are reluctant to take ownership/ responsibility for the adverse impacts they are imposing on the County Town. Ipswich has little power/ control for resolution.

Object

Representation ID: 26347

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Purpose of review is to update the Core Strategy until 2036 taking into account new legislation and NPPF Updates and to align the Local Plan with neighbours. However, EastSuffolk is tasked with making modifications to their plan. SOCS very critical of the ‘Statement of Common Ground’ issued last year and submitted a response to the emerging Mid Suffolk Local Plan Consultation in addition to Suffolk Coastal District Council. SOCS attended and gave oral evidence to the EastSuffolk Plan Inquiry. Feel the Duty to Cooperate has not been effectively achieved within this Draft; nor has it by the partner local authorities.

Object

Representation ID: 26348

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Lack of realistic accounting for the adopted policy on Climate Emergency and the Climate Change agenda, for 10 of the 12 objectives. Specifically in relation to traffic related issues, including delivering the required infrastructure and modal shift and the associated impact on air quality; climate emergency and climate change precipitated flood risk, loss of grade 2 farm land, loss of vital green rim and urban/rural separation with its attendant adverse impacts on the network of wildlife links with green corridors, especially to the County Wildlife site area of the Fynn Valley.

Object

Representation ID: 26351

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Tuddenham Road/Westerfield green corridors are home to significant number of recorded protected species (great crested newts, badgers, hedgehogs, bats and all manner of species) as well as birds, flora/ fauna; Southern Marsh and bee orchids found on the Fynn Valley and adjacent area. Due to private ownership, there is little interest for formal surveys due to landowners aspirations for land use. SWT done some work within Red House Ipswich, the Fynn Valley CWS; a Hedgerow Survey of the whole IGS area completed. Active badger sets reported. Object to change from green rim to green trail as this is misleading.

Object

Representation ID: 26352

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? Yes

Duty to co-operate? Not specified

Tuddenham Road/Westerfield green corridors are home to significant number of recorded protected species (great crested newts, badgers, hedgehogs, bats and all manner of species) as well as birds, flora/ fauna; Southern Marsh and bee orchids found on the Fynn Valley and adjacent area. Due to private ownership, there is little interest for formal surveys due to landowners aspirations for land use. SWT done some work within Red House Ipswich, the Fynn Valley CWS; a Hedgerow Survey of the whole IGS area completed. Active badger sets reported. Object to change from green rim to green trail as this is misleading. Approach to green infrastructure unsound due to constraints of IGS and HDL.

Object

Representation ID: 26353

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

SOCS; “Adverse impacts and significant disruption will undoubtedly occur in both the short and
long term on existing residents’ Quality of Life and Well being”; point conceded by Portfolio holder (paper E/13/601); “ 2.2 The development of the Northern Fringe involves major challenges due to its largescale, multiple ownership, the need to incorporate a wide range of supporting infrastructure and the mitigation of impacts on local communities.” ISPA4 is unjustified/ unsound. Concerns regarding air quality, flood risk vulnerability and biodiversity/ habitat loss. Future households will have to bear costs of management/ maintenance of drainage. Should be levied to new houses.

Object

Representation ID: 26354

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Quotes from SOCS and Portfolio Holder regarding impacts/ challenges (see attached). Concerns regarding air quality, flood risk vulnerability and biodiversity/ habitat loss. Future households will bear costs of management/ maintenance of drainage, levy new houses instead. Concerns on road network to cope with additional traffic without northern relief road. Concerned bridges not built in time 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. Need contingency measures for alternative funding. Delivery of roads must be compatible with traffic modelling.

Object

Representation ID: 26356

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Lacks clarity in respect of flooding risk. In March 2016, SCC Portfolio holder Matthew Hicks confessed the need to work better together (see full quote). Ipswich no longer have their own dedicated drainage engineering department which places them at a disadvantage. There should be a reference to the work of the Food and Farming Commission and to the issue of sustainable land use. See extract. Needs to reflect the legal requirement to comply with Air Quality targets. Climate emergency declaration and carbon neutral commitment need to be referenced to be consistent with Court of Appeal ruling on Heathrow.