Core Strategy and Policies Development Plan Document (DPD) Main Modifications

Object

Representation ID: 26718

Received: 19/09/2021

Respondent: Northern Fringe Protection Group

Legally compliant? No

Sound? No

The proposed modification still fails to include an objective for AIR QUALITY “to contribute towards compliance with relevant limit values” as required under the NPPF (and legally binding air quality legislation). The proposed modification is therefore neither effective, nor consistent with national policy. We suggest that IBC should ensure compliance with legally binding targets by 2024, which would be 16 years since the publication of IBC’s first Air Quality Action Plan in 2008 and consistent with IBC’s current Air Quality Action Plan 2019-2024. The AQAP should have been designed to ensure compliance with legally binding limit values for it to have been approved by Councillors as fit for purpose; so there is no reason why 2024 should not be included in the Plan. If 2024 is not accepted by IBC, then it clearly illustrates that the current AQAP is inadequate and needs to be urgently revised to ensure compliance.

Object

Representation ID: 26719

Received: 19/09/2021

Respondent: Northern Fringe Protection Group

Legally compliant? No

Sound? No

The proposed modification MM77 is insufficient and needs to include a compliance date to be effective and consistent with national policy. We advocate that this is set at end 2023. Without a target date Policy DM3 cannot possibly be effective. We note that paragraph a) repeated below references that Development proposals should not “delay the date at which compliance will be achieved in areas that are currently in exceedance of legal limits”. Consequently a date for compliance must be included in the Plan, otherwise how will compliance with this requirement be assessed?

Object

Representation ID: 26720

Received: 19/09/2021

Respondent: Northern Fringe Protection Group

Legally compliant? No

Sound? No

To be consistent with Policy DM3, MM99 also needs to make it clear that there should not be any “negative impact” on, and around, existing AQMAs from new development or the exceedances of legally binding limit values anywhere in Ipswich. We also not that there is no definition of “significant” and suggest that this needs to be deleted. To be effective and consistent with national policy MM99 needs to be revised (see suggested change).

Object

Representation ID: 26721

Received: 19/09/2021

Respondent: Northern Fringe Protection Group

Legally compliant? No

Sound? No

The reference to “the corporate Air Quality Action Plan Review (Council Target)” should be removed as a) this Review is not in the public domain and b) has not been agreed so it is therefore not yet a Council target. We strongly object to the proposed 2036 date as this will result in further un-necessary deaths and cases of respiratory illness in Ipswich. It is clearly not effective, justified, or consistent with national policy to continue to allow illegal air quality levels in Ipswich for another 25 years. It clearly illustrates that IBC is not taking its air quality duties seriously.
We note that since its first Air Quality Action Plan in 2008, IBC has failed to improve air quality in Ipswich and the number of AQMAs has been increased from the initial three AQMAs.

Also note that this target could be achieved by reducing just one of existing AQMAs by just 1m2. The Executive Summary of IBC’s current Air Quality Action 2019-2024 states that “Ipswich Borough Council is committed to reducing the exposure of people in Ipswich to poor air quality in order to improve health.” This target is therefore inconsistent with IBC’s own AQAP as it illustrates no real commitment to reducing the exposure of people in Ipswich to poor air quality. It is clearly worthless and needs to be replaced with a target that will ensure compliance with UK air quality legislation and NPPF paragraph 186.