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Natural England is generally supportive of the proposed amendments to Policy CS10: Ipswich Garden Suburb, including additional clarification relating to infrastructure provision to comply with Habitats Regulations requirements, in the supporting text. As stated in our Written Statement to Address the Inspector's Questions (27 May 2016), whilst we consider this policy to be sound, we recommended that bullet point (b) be re-worded as follows:
'amplify the infrastructure that developments will need to deliver on a comprehensive basis alongside new housing, including community facilities, green space, the Country Park and, at an appropriate stage, the provision of a railway crossing to link potential development phases, in the interests of sustainability and integration'.
Natural England advises your authority to give further consideration to the inclusion of this additional wording to strengthen the certainty of delivery of green space and the Country Park through the Garden Suburb development.
As highlighted in our Written Statement to Address the Inspector's Questions Natural England supports the proposed amendments to Policy CS17 as follows:
'The council will seek contributions to ensure that the mitigation measures identified in the Habitats Regulations Assessment and in the Recreational Avoidance and Mitigation Strategy can be addressed and delivered including for any measures not classified as infrastructure'.
Natural England also welcomes the proposed inclusion of additional text to confirm that
'The Council will produce a Recreational Avoidance and Mitigation Strategy by March 2017, which will specify the measures required and how these will be delivered'.
We believe that these amendments sufficiently strengthen Policy CS17 in line with advice provided through our Statement of Common Ground, submitted for the Local Plan Examination. Accordingly we now consider this policy to be sound and legally compliant with the Habitats Regulations Assessment.
As alluded to in previous correspondence we support the following proposed modification to Policy DM29: Provision of New Open Spaces, Sport and Recreation Facilities:
On small, high density infill developments of 15 to 40 dwellings, the requirement for 15% on-site open space provision will be applied flexibly where it can be demonstrated that compliance would reduce the number of dwellings that can be delivered.
Post-Submission Main Modifications to Proposed Submission Site Allocations and Policies (incorporating IP-One Area Action Plan) DPD
Natural England has no specific comments to make on the Post-Submission Main Modifications to the Site Allocations plan as these do not appear to affect issues within our remit.
Habitats Regulations Assessment Addenda
We have reviewed the HRA Addendum for the Core Strategy and Policies Development Plan Document review post-submission main modifications (Landscape Partnership, October 2016). One policy modification was considered to have potential to result in a change which might give rise to a likely significant effect upon European sites. Modifications to policy CS7 and supporting text seek to reduce the housing allocation from 677 dwellings per year, to an interim minimum target of 489 dwellings per year. The 677 dwellings per annum assessed in the previous HRA was not expected to have an adverse effect, therefore the lower figure of 489 would also not be expected to have an adverse effect. Consequently Natural England agrees with the conclusion of the HRA Addendum that impacts of housing growth on European sites would therefore be similar to or less than that assessed for the Proposed Submission draft.
We have reviewed the HRA Addendum for the Site Allocations and Policies (Incorporating IP-One Area Action Plan) post-submission main modifications (Landscape Partnership, October 2016). The assessment identifies that no policy modification was considered to have potential to result in a change likely to have a significant effect upon European sites. Natural England agrees with this assessment and supports the conclusion that there would be no adverse effect upon any European site arising from the Local Plan document, as modified following the Examination, and no further detailed consideration is required.
SA Report Addendum - Post Submission Main Modifications
The report identifies that Post Submission Main Modifications have not resulted in any significant changes to the effects identified or the proposed monitoring framework identified in the Proposed Submission SA
Report and no further mitigation measures are considered necessary. Natural England is satisfied with this conclusion.

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