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."