Object

Representation ID: 25745

Received: 12/03/2019

Respondent: Environment Agency

We are pleased to see the inclusion of Policy CS1 regarding sustainable development. Paragraph 8.20 refers to nationally and internationally protected landscapes and habitats. The wording here should be amended to say that "A particular issue is the need to ensure that new development does not result in harm to individual designated sites or the integrity of the network of locally, nationally and internationally designated sites, namely Local Wildlife Sites, Sites of Special Scientific Interest, Special Protection Areas, Special Areas of Conservation and Ramsar sites".

Object

Representation ID: 25750

Received: 12/03/2019

Respondent: Environment Agency

Paragraph 8.37 refers to outdated climate projections as it refers to UKCP08. UKCP18 has now been released and should be referred to. Further information can be found on the MetOffice website here: https://www.metoffice.gov.uk/research/collaboration/ukcp.
The Local Plan should ensure that any potential impacts that may arise as a result of applying new climate change allowances are considered.

Object

Representation ID: 25752

Received: 12/03/2019

Respondent: Environment Agency

Paragraph 8.40 refers to tidal risk being addressed and mentions that there is still a residual risk. The wording should be further enhanced by also referencing any fluvial flood risk from the River Gipping.

Support

Representation ID: 25754

Received: 12/03/2019

Respondent: Environment Agency

We welcome reference to the local Water Cycle Study (WCS) and the local surface water management plan within paragraph 8.41 of the Local Plan. The WCS will serve as an evidence base to support the local plan and should suggest policies and measures to enable the delivery of all proposed development.

Object

Representation ID: 25755

Received: 12/03/2019

Respondent: Environment Agency

Therefore, we would expect to see a summary of the findings and recommendations of the WCS and surface water management plan within the local plan. Any areas of concern in terms of waste water and sewerage infrastructure provisions should be highlighted and details of how development will be dealt with sustainably within the Borough provided in accordance with NPPF paragraph 20 section b. It should however be noted that the Haven Gateway Water Cycle Study is now 10 years old, this should be taken into consideration when referring to the WCS.

Object

Representation ID: 25756

Received: 12/03/2019

Respondent: Environment Agency

If the Water Cycle Study is updated, this should be referred to when the local plan is updated. The paragraph could be enhanced by referencing that development should be phased in line with infrastructure upgrade timescales, thus ensuring adequate waste and water infrastructure is in place to accommodate the demands from additional growth in the borough.

Object

Representation ID: 25786

Received: 13/03/2019

Respondent: Home Builders Federation Ltd (HBF)

When the NPPF was first published Councils were advised by the Planning Inspectorate to include some 'model' wording in local plans with regards to the presumption in favour of sustainable development. However, it is our understanding that this advice has since been rescinded and that such statements are no longer a requirement of local plans. Given this position and the fact that S1 repeats national policy it should be deleted.

Object

Representation ID: 25898

Received: 12/03/2019

Respondent: On behalf of SSE Generation Development Ltd

Policy CS1 is in favour of Sustainable Development and this is supported.

SSE is of the view that wind energy will continue to contribute significantly towards efforts to reduce carbon emissions and help tackle climate change. It is considered that the Local plan should give further focus to wind energy and the benefits it can bring.

Furthermore, an evidence based and site specific approach should be taken to further wind energy developments rather than a reliance on landscape capacity studies. Consideration should be given not just to landscape but also the information contained within an EIA and supporting planning documentation.

Object

Representation ID: 25901

Received: 12/03/2019

Respondent: Environment Agency

We would like paragraph 8.43 to include some text about the benefits of trees for rivers. Trees are important in helping to keep rivers cool and therefore improving the state of the river for biodiversity. By providing shade, trees are able to moderate the extremes in water temperature which can be detrimental to fish spawning. Their underwater root systems provide valuable habitat to fish and invertebrates whilst stabilising the banks. Shading can also be helpful in the control of aquatic vegetation and well as bringing benefits for people.

Object

Representation ID: 25902

Received: 12/03/2019

Respondent: Environment Agency

Green spaces and functioning ecosystems are referenced in paragraph 8.44. This paragraph could be enhanced by specifically referring to blue corridors (such as the River Gipping) here too. Blue corridors promote the idea of 'making space for water' and can involve setting back urban development from watercourses, overland flow paths and ponding areas creating a mosaic of urban corridors designed to facilitate natural hydrological processes whilst minimising urban flooding, enhancing biodiversity and improving access to recreation.

Object

Representation ID: 26045

Received: 13/03/2019

Respondent: Historic England

The supporting text makes no mention of the inherent sustainability of keeping historic buildings in use.

Object

Representation ID: 26099

Received: 01/04/2019

Respondent: Suffolk Constabulary

The first sentence refers to climate change. It has been estimated that the carbon cost of crime within the UK is in the region of 6,000,000 tonnes of CO2 per annum, roughly equivalent to the total CO2 output of 6 million UK homes. Reducing crime not only improves the quality of the environment for those who live in, work in and visit the borough, but can also have a direct impact on CO2 production. Designing out crime should be given greater emphasis throughout the plan. For example, the second paragraph of this opening Policy could be amended (see full text).

Object

Representation ID: 26143

Received: 13/03/2019

Respondent: Clean Air Ipswich

The Climate Change Committee (CCC) states from 2025 at the latest, no new homes should be connected to the gas grid. The Plan should show that this is the intention and the date which this will happen.

The general proposals by the CCC should be included (see references).

Similar to national targets, local targets between authorities and universities should be set on climate change. What discussions have IBC had?