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;