ipswich.gov.uk
Object
Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft
Representation ID: 26593
Received: 02/03/2020
Respondent: Suffolk County Council
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
NPPF p.165 states “Major developments should incorporate sustainable drainage systems unless there is clear evidence that this would be inappropriate.” DM4a) states “... and wherever practicable appropriate application of Sustainable Drainage Systems (SuDS)”. Planning practice guidance paragraphs 082 and 083 uses the term “practicable” in reference deciding the most appropriate type, operation and maintenance of SUDS on a site, not the principle of using SUDS . The guidance makes a distinction between the terms "inappropriate” and “practicable”. The current wording of the policy is not consistent and could cause confusion. The words “where practicable” should be removed from the policy.
The words “where practicable” should be removed from the policy. The SFRA needs further work arising from Environment Agency data. SCC will assist the Borough in further developing this piece of evidence.