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

Object

Representation ID: 26359

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Objective1; inadequately demonstrated. Objective 2; the 4% and 5% affordable housing negotiated on IGS doesn't match with the 31% quoted. Evidence of recent job losses in town undermines credibility of job target. Objective 3; Lack of justification for HDL. Objective 5; Concerns about railway noise/ vibration from intensification of line and traffic from humpback bridge. Current rail noise causes residents complaints and audible for a distance of about 1/4-1/2 a mile at night causing significant sleep-disturbance especially in summer. 5 point rail plan agreed 2018 and no assessment of diesel pollution. Adopted indicator of air quality exceedances should be reinstated.

Object

Representation ID: 26362

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Objective 6:
1. Junctions/ link roads at/near capacity, not addressed. No evidence growth is sound.
2. Severe capacity issues in 2026 but no infrastructure projects in Infrastructure Tables. Especially town centre, Ipswich Garden Suburb and A1214.
3.Modelling fails to identify when junctions will reach capacity.
4. Failing to Improve Access in breach of CS5. Modal Shift assumptions too high, uncompliant with CS20.
5. CCC assumes 10% modal shift by 2050. No evidence 15% modal shift deliverable by 2026? CCC assumption should be used.
6. Existing walking/ cycling infrastructure substandard, won't enable delivery of modal shift. Need new cycling indicator.

Object

Representation ID: 26363

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Objective 6 (continued)
7. No funding allocated in IBC’s financial plan to encourage modal shift.
8. Doesn't include proportionate evidence. New Evidence database incomplete as excludes Transport documents, especially modal shift related and S106 schedules for approved IGS developments which haven't been made publicly available.
9. Concerned that road bridges (and country park) may not be delivered in time (February 2022) to receive £9.8m HIF. If so, then CS is unsound unless alternative funding available.
10. Not positively prepared as fails to fully assess transport infrastructure requirements, especially in relation to timing of delivery (including sewage).

Object

Representation ID: 26364

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

IBC is failing to Improve Access in breach of CS5. More needs to be done otherwise Modal Switch assumptions too high and unsound. CS is not justified with respect to Improving Access and Transport. concerned that our comments on CS5 and CS20 in relation to the transport modelling and modal shift (and associated air quality issues) have not been adequately considered. disappointing that the Transport Mitigation Strategy and other relevant modal shift documents have not been included in the Evidence Base. new infrastructure required is substantially underestimated as is the difficulty in achieving the unprecedented levels of modal shift necessary.

Object

Representation ID: 26365

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

IBC is failing to Improve Access in breach of CS20. More needs to be done otherwise Modal Switch assumptions too high and unsound. CS is not justified with respect to Improving Access and Transport. Concerned our comments on CS20 in relation to the transport modelling and modal shift haven't been adequately considered. Transport Mitigation Strategy and other relevant modal shift documents not included in Evidence Base. New infrastructure required is substantially underestimated as is the difficulty in achieving the unprecedented levels of modal shift necessary. See detailed comments on Transport Modelling and Mitigation Strategy (pages 26 - 32). Amend 8.241.

Object

Representation ID: 26367

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Objective 5:
1. Inconsistent with national policy, fails to comply with legal limits. Must be requirement.
2. Strengthen commitment to Improve Air Quality, no real improvement over past decade.
3. No funding in IBC’s financial plan for improving air quality.
4.No AQA. Must be completed urgently. Include assessments for early years of developments, construction-related traffic and rail/sea traffic and impacts of different levels of modal shift rather than unsubstantiated levels assumed.
5. Little point undertaking an AQA in 2036 as ban on non-electric vehicles. Early years likely to be worst. Suggest earlier assessment.
6. Ambiguity over 2004 emission levels cited.

Object

Representation ID: 26370

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Objectives 4 and 9; At the Executive meeting 9th July 2019 Ipswich Borough Council Declared a Climate Emergency. The CS needs to be updated to incorporate this to be sound.

Object

Representation ID: 26371

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We strongly object to the re-designation of the Ipswich “green rim” to “green trails”. This is in breach of DM13 and unsound.

Object

Representation ID: 26372

Received: 02/03/2020

Respondent: Save Our Country Spaces

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The current situation regarding flood risk assessment within the CS is ambiguous and somewhat confused. This needs to be clarified and made clearer so that any required actions can be properly identified and included in the CS for it to be sound and understood by residents.(see image of better map to illustrate.)

Object

Representation ID: 26379

Received: 02/03/2020

Respondent: Save Our Country Spaces

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.