Object

Representation ID: 25959

Received: 12/03/2019

Respondent: Environment Agency

Chapter 11 - Key Targets associated with Part B
The key targets of the plan are outlined on pages 155 to 159. We welcome the inclusion of objective 1 which aims for high standards of design in new development and ensures that development is sustainable, environmentally friendly and resilient to the effects of climate change. The objective could be further enhanced by referencing property level protection to this objective.

Object

Representation ID: 25960

Received: 12/03/2019

Respondent: Environment Agency

Objective 1 We support the use of SuDS in this objective however it is important to be clear that SuDS, if soaking into the ground, may not be suitable at some sites. Non-infiltration SuDS should be used where contamination is present or groundwater levels are too high.

Object

Representation ID: 25961

Received: 12/03/2019

Respondent: Environment Agency

We are pleased to see reference to the Ipswich tidal barrier in objective 7. The objective states that the implementation of the barrier is due by the end of 2019. We are pleased to say that construction is now complete and the barrier is operational. Therefore, this objective should be updated accordingly.

Object

Representation ID: 25962

Received: 12/03/2019

Respondent: Environment Agency

Objective 8 states that there is no net loss of natural capital by 2036. This should be more ambitious to reflect net gain principles in accordance with paragraph 170 of the NPPF. Any impact on biodiversity from human activities and development need to be balanced by at least equivalent gains for biodiversity.

Object

Representation ID: 25963

Received: 12/03/2019

Respondent: Environment Agency

The current objectives do not count for all of the environmental impacts of development in the borough. EA suggests the following:

1 Ensure the protection and enhancement of the environment by endeavouring to meet the objectives of key environmental legislation. This should include the promotion of measures supporting climate change adaptation, delivery of air quality targets, delivery of WFD objectives and flood risk management, including SuDS and water quality.

2 To allow sustainable growth, ensure adequate utilities infrastructure is provided in a timely and efficient manner, ahead of the occupation of developments in order to safeguard the local water environment.

Object

Representation ID: 25964

Received: 12/03/2019

Respondent: Environment Agency

In addition, EA would also welcome the addition of wording stating that areas of brownfield land be brought back to beneficial use in accordance with NPPF paragraph 118 section c.