Object

Representation ID: 798

Received: 12/06/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

The SA/SEA process requires an examination of the baseline information of the Borough as it is now together with data on how it may change in the future. The CS and its SA must therefore be based on the best data available, which is not the case as it fails to utilise the most recent DCLG or EEFM 2013 forecasts. Both the CS and this SA are therefore unsound.

Object

Representation ID: 799

Received: 12/06/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

The SA must be revised to take account of new Governmental guidance on the NPPF, issued following the Ministerial Statement of 6th March 2014. Changes include: issuing guidance on flood risk; clarifying that local plans can be sound where authorities cannot identify housing land for years 11-15; allowing windfalls to be counted over the whole plan period and student/older persons' housing and the reuse of empty homes to be included when assessing housing need; ensuring that infrastructure is provided to support new development; stressing the re-use of brownfield land; and clarifying the issue of prematurity in relation to draft plans.

Object

Representation ID: 800

Received: 12/06/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

Sections 2.3.9 and 2.3.12 fail to identify from the 2013 Suffolk Growth Strategy (sections 2.26, 4.2, 4.4 & 4.5 refer) the need to 'transform skills from a growth barrier to a growth stimulus' and 'Boost educational attainment, aspiration and employability'.

Object

Representation ID: 801

Received: 12/06/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

Table 2-2 There are serious flaws/omissions in this summary of sustainability issues and opportunities that need to be corrected, especially in relation to the use of obsolete data. E.g. it needs to better represent low education standards in Ipswich, not underplay the issue; use better health data e.g. from AMR; address wastewater issues; acknowledge that air quality is worsening in Ipswich and factor in the effect of traffic from the Northern Fringe; acknowledge that Ipswich is not well connected; use better data on pay/benefits; address worsening deprivation; and include empty homes and stock condition data.

Object

Representation ID: 802

Received: 12/06/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

Table 2-3. Suggest improvements to objectives and indicators. See full text, but examples include: ET1 should include an indicator to measure congestion as the main cause of air pollution. ET2 the key issue is whether development will harm soil resources/quality which Hyder have omitted. HW1 better indicators would be levels of physical activity and GP registrations for depression. ER1 should ask whether developments will improve existing areas of deprivation. ER2 should add indicators for number of long term unemployed and average wage. ER3 should look at privately rented houses falling below EPC rating 'E'. Consider consequent changes to Table 2-4.

Object

Representation ID: 803

Received: 12/06/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

Paragraph 2.3.27 There will obviously be an increase of traffic during the construction / operation of new residential development associated with an increase of inhabitants and their future transport requirements, therefore this will obviously affect local air quality and climate change. This paragraph needs to be amended accordingly. If not please justify why Hyder thinks there might be no increase in traffic at all.

Object

Representation ID: 804

Received: 12/06/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

Paragraph 2.3.25 These are not "uncertainties" but likely outcomes unless further mitigation steps are implemented. The SA underestimates the impact of Objective ER3, which is incompatible with: ET1 improve air quality, ET2 conserve soil, ET3 reduce waste, ET4 reduce the effects of traffic upon the environment, ET6 limit and adapt to climate change, ET7 protect and enhance the quality of water and reduce the risk of flooding, and ET8: conserve and enhance biodiversity and geodiversity. E.g. under ET1 the number of AQMAs is increasing in Ipswich and the Northern Fringe will adversely impact on those north of the town centre.

Object

Representation ID: 805

Received: 12/06/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

Scoping Report and Paragraph 2.3.35 We have a number of concerns that our previous comments on the Scoping Report have not been adequately addressed and need to be revisited as a priority. We have included these in Appendix 1 using the original numbering with an explanation of our concerns in red. See appendix for full text.

Object

Representation ID: 806

Received: 12/06/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

Paragraph 2.4.4 The removal of a PDL target from Policy CS9 is a major change and therefore needs to be part of the SA.

Object

Representation ID: 807

Received: 12/06/2014

Respondent: Northern Fringe Protection Group

Number of people: 323

Paragraph 3.1.1 The original SA was flawed because it did not look at alternatives to the Policies other than "do nothing". The SA of the revised CS must assess alternatives to the policies in order to be sound.