Resident's Groups, SOCS & North Fringe Protection Group (NFPG), have submit detailed comments

The  Planning Committee is scheduled to meet and decide on this CREST application on 4th April, the day after after the Easter Bank holiday.

The committee papers which are available, state that the CREST Environmental Statement Update on Air Quality consultation does not finish until 5th April............. the day AFTER the Planning meeting.

https://ppc.ipswich.gov.uk/xappnletters.asp?pageNumber=1&iappID=16%2F00608%2FOUT&

The SOCS submissions to the consultation will be uploaded here as well:
 https://drive.google.com/open?id=1e6s2lM6Xx1jzB69LP4W6x8m_J4AuI5bb

 https://drive.google.com/open?id=1K6fx74i4TEUP3JrEeR8JQV19jbL1jfkK

The North Fringe Protection Group's  submission is not showing on the IBC website, but all the content is contained in the Appendix which can be viewed above.

Respond to Ipswich Borough by email on CREST Application by 29th March

Email to development.managment@ipswich.gov.uk

Land North Of Railway And East Of Henley Road Ipswich - 16/00608/OUT

& (Land south of Railway IP14/00638/OUTFL- LATE REPRESENTATION) 

Name                                                      Address                                                   Objection        Date



 CREST development- renewed public consultation on Air Quality

Application Supporting Documents

ENV STAT 13 AQ ADDENDUM

Environmental Statement Addendum - Air Quality

22.02.2018

2 Mb

“Henley Gate Air Quality 13.0 AIR QUALITY Introduction 13.2 Updates of local air quality monitoring data and an update in vehicle emissions factors and background data have been taken into account. Consideration has also been given to a new Air Quality Management Area (No. 5) declared in September 2017. “This additional information has been prepared by Peter Brett Associates (PBA). Information has been provided only where required, otherwise the original information still stands and has not been repeated here.

It is felt that the addendum still fails to address existing concerns-detailed below.

 

CREST (& MERSEA and IBC) are reliant on methodology, estimations and projections, based on the DEFRA guidance and policy (2015) which has been found to be inadequate and unlawful 3 times by the Courts and Supreme Court ruling on Air Quality and compliance with the EU Directive. 

Until there is an up to date IBC Air Quality Action Plan adopted, which demonstrates compliance with the recent Supreme Court and other landmark legal decisions, IBC would be ill advised in “determining” or processing any Ipswich Garden Suburb or other large scale applications. 

IBC are "in the process” of drafting a new Air Quality Action Plan - but this will not be done for some months. Neither IBC nor Suffolk County Council have up to date sufficient and reliable measured data and guidance from DEFRA currently on which to base decisions. 

Any determination or referral to the Planning and Development Control Committee should be delayed until the Air Quality Action Plan is adopted.
IBC could face a legal challenge on an “unsound” planning approval which overlooks or overrides this imperative. 

3 sound reasons to OBJECT to both REPRESENTATION); 
 
1. DEFRA1 say Air Quality & particulate pollution is worse in Ipswich than in London.
2. House of Commons: March 7th 2018- "Improving air quality report"Environment, Food and Rural Affairs, Environmental Audit, Health and Social Care, and Transport Committees 2
States, "The Government cannot continue to put public health at risk. "
1"Where is Britain’s worst air pollution?" https://www.theguardian.com/environment/2017/sep/10/uk-flouting-duty-to-cut-air-pollution-deaths-says-un-human-rights-report#img-1  http://www.eadt.co.uk/news/air-pollution-kills-more-than-60-people-a-year-in-ipswich-but-could-new-court-ruling-help-campaigners-fight-this-hidden-killer-1-4082803
2 https://publications.parliament.uk/pa/cm201719/cmselect/cmenvfru/433/433.pdf

From the Improving air quality report:the detrimental effects on air quality from a series of policies by successive governments over many years has led to a number of court cases against the UK Government. There is an urgent need for national leadership and consensus-building to bring about a step change in how the problem of air quality is tackled.The Government cannot continue to put public health at risk. 

It needs to place the protection of public health and the environment, rather than technical compliance or political convenience, at the centre of air quality policy.
3. Suffolk Public Health published concern in their 2017 Annual Review.
https://www.healthysuffolk.org.uk/jsna/reports/jsna-topic-reports/air-quality 

1. It is estimated that 118 people die early in Suffolk every year because of particulate air pollution.
2. Car drivers are exposed to twice as much air pollution as pedestrians, and nine times as much as cyclists.They feel it is non-compliant with the Supplementary Guidance for Air Quality Management and New Development 2011 produced by the Suffolk Local Authorities

 
The application(s) 16/00608/OUT ( and IP14/00638/OUTFL:LATE REPRESENTATION

1. fails to consider the construction phase
2. do not consider the phased nature of the development (ie part occupation, part construction)
3. fails to assess the cumulative impact of the IGS, including construction traffic, during the phased
build out
4. assessments use a baseline which is lower than current emission levels and hence under-
estimates current emission levels and future emission levels
The environmental assessment clearly fails to meet several of the "Criteria for Evaluating Whether an
Air Quality Assessment is Adequate"; (Box 3 of the Supplementary Guidance for Air Quality
Management and New Development adopted by Ipswich Borough Council and Suffolk County Council). 

Suffolk County Council Public Health have statutory powers over particulate matter and risk from
pollution outlined in their Public HealthOutcomesFramework. https://www.healthysuffolk.org.uk/jsna/reports/jsna- topic-reports/air-quality
"Planned growth and development in Suffolk is expected to increase the burden of air pollution across the county in the coming decades. If this proceeds without adequate work to prevent, mitigate and offset its impact on air quality, we risk putting public health in danger by compromising our generally good air quality."
Other Comments;

So what's new on Air Quality & what has changed regarding Ipswich's expansion, development proposals, CREST's (and Mersea Homes) renewed Planning Applications, to address Air Pollution risk?

Answer-Nothing much which will resolve difficulties in Ipswich.

In fact, currently there is evidence of further  measured deterioration of Air Quality in Ipswich (NOx) and worryingly high estimates of harming particulates.

The Supreme Court has determined the continued UK's failure of legal compliance with the EU Air Pollution Directive, which effectively renders DEFRA's guidance to Local Authorities "unfit for purpose" and therefore, we say local evidence is unfit for purpose and inadmissible. 

Royal Courts of Justice Wednesday, 21st February 2018

High Court ruling on remedies in ClientEarth's third clean air case against the UK government.

 Extract;

"2. Four matters remain in dispute. First, the terms of the declaratory relief. In my view, it is necessary for the sake of clarity to set out in full the respects in which the 2017 Plan was unlawful, as I have done in the judgment. It follows that I prefer the claimant's formulation on declaratory relief rather than the summary form offered by the Secretary of State."

"

12. Here I am faced, despite the substantial progress that has been made, with a continuing failure by the government to meet its obligation to reduce air pollution. As I pointed out in the judgment in this case, it is now eight years since compliance with the 2008 Directive should have been achieved and the 2017 Air Quality Plan is the third unsuccessful attempt the government has made at devising a plan which complies with the Directive and the domestic regulations. All the while, the health of those living in the towns and cities of this country is at real risk." 

NB. Ipswich's last Action Plan on Air Quality is dated 2008.

"In December 2016, Ipswich Borough Council re-commenced automatic (continuous) nitrogen dioxide monitoring after a 2 year hiatus." ie two year data gap!

SCC Public Health seems to support our concerns.
 https://www.healthysuffolk.org.uk/jsna/reports/jsna-topic-reports/air-quality

Cross-party MPs demand urgent action to deal with UK “air quality catastrophe”

News / 15 March 2018
 https://www.clientearth.org/cross-party-mps-demand-urgent-action-to-deal-with-air-quality-catastrophe/

"Four select committees have released the findings of a joint inquiry into UK air quality, calling for a series of measures to address illegal pollution. It is a humiliating read for the UK government.
Responding to the report, ClientEarth Head of Public Affairs Simon Alcock said: “We are delighted that this landmark report from a cross-party group of MPs has called on the government to urgently take further action to fix the dangerous air pollution in our towns and cities. It highlights the lack of national leadership by successive governments to tackle this public health crisis – it was supposed to be resolved over eight years ago."

So things are definitely not sorted yet........

-------------------------------------------------------------------------------------

The 2017 transcript of SOCS statement on the CREST Application at the Planning committee February 2017 below suggests why residents still feel that this application should not be determined nor go to committee until Ipswich has sorted out it's  new "Action Plan" on Air Pollution;

A relevant and related Application 
 

"Amended Planning Application IP14/00638/OUTFL as amended April 2017 Land To South Of Railway Line, Westerfield Road, Ipswich, Suffolk
SOCS wish their response to 16/00638/OUT be recorded as an Unreserved Objection. 

SOCS OBJECTIONS :Air Quality (and Climate Change Agenda) - AIR POLLUTION and adverse health impacts are SOCS key concern

SOCS representing the lay public, felt  expert opinion was necessary in order to to qualify their concerns and criticisms from Dr Benjamin Barratt Lecturer 6in Air Quality Science and Roger Richards7 former Principal Engineer with Ricardo Consulting Engineers. 

Dr Barratt confirmed the legal requirements that no existing LAQMA should be further adversely impacted by further developments.

Mr Richards states, “I’ve read through the IBC (WSP)AQ report. It’s very poor. Here’s a summary of the main flaws in the document (5 points -See Appendix F).....Any one of these failings would render the report unreliable. Taken together they render it completely meaningless.” 

The WSP Reports suggest there is only a “moderate” predicted problem regarding traffic impacts and air quality. We can’t see this to be the case. We do not trust the “reassurances” contained in the reports. The experts above agree there are causes for concern.
SOCS believe Air Pollution impacts to be critical to our local area and local population.
We believe they are an uncomfortable truth which is currently at risk of being “buried”.
Future expansion of Ipswich

No Public Health Impact Assessment study from traffic and air quality has been done of the proposed expansion despite being requested by us.

CREST development- renewed public consultation on Air Quality

Land North Of Railway And East Of Henley Road Ipswich - 16/00608/OUT   

 

Respond by  29th March 2018 

https://www.ipswich.gov.uk/services/planning-applications

Actual Committee Date 4th Apr 2018 

 https://ppc.ipswich.gov.uk/xappndocs.asp?iAppID=16/00608/OUT

Application Supporting Documents

ENV STAT 13 AQ ADDENDUM

Environmental Statement Addendum - Air Quality

22.02.2018

2 Mb

Henley Gate Air Quality

13.0 AIR QUALITY Introduction

1. 13.1  This addendum provides additional information of the potential impacts of the Proposed Development at Henley Gate (16/00608/OUT) in relation to Air Quality. This addendum should be read alongside the assessment within Chapter 13 of the Environmental Statement submitted in June 2016. This additional information has been prepared by Peter Brett Associates (PBA). Information has been provided only where required, otherwise the original information still stands and has not been repeated here-in.
   
2. 13.2  Updates of local air quality monitoring data and an update in vehicle emissions factors and background data have been taken into account in. Consideration has also been given to a new Air Quality Management Area (No. 5) declared in September 2017.
   

Here are 3 sound reasons why you should consider commenting on this.

 1. DEFRA say Air Quality & particulate pollution is worse in Ipswich than London.

 

"Where is Britain’s worst air pollution?"

 https://www.theguardian.com/environment/2017/sep/10/uk-flouting-duty-to-cut-air-pollution-deaths-says-un-human-rights-report

http://www.eadt.co.uk/news/air-pollution-kills-more-than-60-people-a-year-in-ipswich-but-could-new-court-ruling-help-campaigners-fight-this-hidden-killer-1-4082803

2. House of Commons: March 7th 2018- "Improving air quality report"

Environment, Food and Rural Affairs, Environmental Audit, Health and Social Care, and Transport Committees

 https://publications.parliament.uk/pa/cm201719/cmselect/cmenvfru/433/433.pdf

Local MPs were involved with this report; Dan Poulter, Sandy Martin and Theresa Coffey.

States, "The Government cannot continue to put public health at risk. "

From the  Improving air quality report;

• The detrimental effects on air quality from a series of policies by successive governments over many years has led to a number of court cases against the UK Government. 
• There is an urgent need for national leadership and consensus-building to bring about a step change in how the problem of air quality is tackled.
  The Government cannot continue to put public health at risk.
•  It needs to:Place the protection of public health and the environment, rather than
  technical compliance or political convenience, at the centre of air quality policy.

3. Suffolk Public Health published concern in their 2017 Annual Review.

https://www.healthysuffolk.org.uk/jsna/reports/jsna-topic-reports/air-quality
1. It is estimated that 118 people die early in Suffolk every year because of particulate air pollution.
2.  Car drivers are exposed to twice as much air pollution as pedestrians, and nine times as much as cyclists.

Local views from Save Our Country Spaces (SOCS) and the North Fringe Protection Group (NFPG)

It is felt that the addendum still fails to address existing  concerns. A full detailed objection will be submitted.

They feel it is non-compliant with the Supplementary Guidance for Air Quality Management and New Development 2011 produced by the Suffolk Local Authorities;
 

1. it fails to consider the construction phase

2. it does not consider the phased nature of the development (ie part occupation, part construction)

3. it fails to assess the cumulative impact of the IGS, including construction traffic, during the phased build out

4. the assessment uses a baseline which is lower than current emission levels and hence under-estimates current emission levels and future emission levels

The  environmental assessment clearly fails to meet several of the "Criteria for Evaluating Whether an Air Quality Assessment is Adequate"; (Box 3 of the Supplementary Guidance for Air Quality Management and New Development adopted by Ipswich Borough Council and Suffolk County Council). 

CREST (and IBC) are reliant on methodology, estimations and projections, based on the DEFRA guidance and policy which was found to be inadequate and unlawful by the Supreme Court ruling (UK to Air Quality and compliance with the EU Directive).

SOCS argue that until there is an up to date IBC Air Quality Action Plan adopted, which demonstrates compliance with the recent Supreme Court and other landmark legal decisions, IBC would be ill advised in “determining” or processing any  IGS or other large scale applications. 

IBC  could face a legal challenge on an “unsound” planning approval which overlooks or overrides this imperative.

IBC are "in the process” of drafting an new Air Quality Action Plan - but this will not be done for some months. Neither IBC nor  Suffolk County Council have sufficient and reliable measured data, currently.

Any determination or referral to the Planning and Development Control Committee should be delayed until the Action Plan is adopted.

Suffolk County Council Public Health have statutory powers over particulate matter and risk from pollution outlined in their Public Health Outcomes Framework. 

https://www.healthysuffolk.org.uk/jsna/reports/jsna-topic-reports/air-quality

"Planned growth and development in Suffolk is expected to increase the burden of air pollution across the county in the coming decades. If this proceeds without adequate work to prevent, mitigate and offset its impact on air quality, we risk putting public health in danger by compromising our generally good air quality."