Object

Representation ID: 25622

Received: 08/03/2019

Respondent: Suffolk Wildlife Trust

We support the intentions of this policy. However, the text in relation to SSSIs does not appear to be compliant with NPPF paragraph 175(b).

The Priority Habitats and Species sections must also include reference to development delivering ecological enhancements as part of their design and implementation. Enhancements for species such as swifts and hedgehogs should be secured as part of new residential developments.

The intention in the final sentence to encourage development to enhance the ecological network where possible is not supranational enough. All new development should deliver ecological enhancements as per the NPPF (paragraph 170(d)).

Object

Representation ID: 25630

Received: 08/03/2019

Respondent: Suffolk Wildlife Trust

Paragraph 9.8.3 states that there are 19 County Wildlife Sites in the Borough, however policy CS4 states that there are 20. This should be checked for consistency.

Object

Representation ID: 25764

Received: 12/03/2019

Respondent: Natural England

Support this policy. We highlight the importance of measurable net gain in the creation of habitat and improvements to biodiversity and refer you to the Defra 25 YEP and paragraph 174 of the National Planning Policy Framework

We advise that Policy ISPA3 is referenced in Policy DM8 as it affords the protection of designated sites by providing a mechanism to offset recreational disturbance impacts.

Object

Representation ID: 25776

Received: 12/03/2019

Respondent: RSPB

We support the measures to enhance conditions for biodiversity.

The text relating to European (Natura 2000) sites under Sites of international and national importance does not correctly capture the step-wise process of the Habitats Regulations. The reference to 'in-combination effects' should remain (not marked as deleted); it is silent on the 'absence of alternative solutions' and should refer to compensatory measures that would be required should IROPI be concluded.

Paragraph 9.82 - line 2: Add Birds and Habitats Directive
line 10: Amend to 2017 (from 2010)

Object

Representation ID: 25858

Received: 12/03/2019

Respondent: Ravenswood Environmental Group

The policy causes a conflict with the allocations policies because the allocations will have an adverse impact on European Protected sites. The huge housing and industrial development at Ravenswood could be located on an alternative site that would cause less harm to the SPA so Policy DM8 mandates that the Ravenswood development should be refused. The plan therefore unreasonably allocates land for development whilst including policies which would see that development rejected.

Object

Representation ID: 25947

Received: 12/03/2019

Respondent: Environment Agency

DM8 - The Natural Environment- should be refined to say that "Sites of Special Scientific Interest (SSSI) will be protected from development". Similarly, the policy wording for the planning permission section should be strengthened to state that "planning permission will not be granted for development that would result in damage or loss in extent or otherwise have significant adverse effect on Local Nature Reserves or Local Sites".

Object

Representation ID: 25948

Received: 12/03/2019

Respondent: Environment Agency

Policy DM8 - The Natural Environment - the sixth paragraph should be strengthened to say "Enhancements for protected sites and protected and priority species will be expected from new development". The wording of the final paragraph in the policy should be strengthened to say "Within the buffer zones around core areas and corridors, development will be required to enhance the ecological networks through measures such as wildlife beneficial landscaping".

Object

Representation ID: 25949

Received: 12/03/2019

Respondent: Environment Agency

DM8 - The Natural Environment. The wording of the final paragraph in the policy should be strengthened to say "Within the buffer zones around core areas and corridors, development will be required to enhance the ecological networks through measures such as wildlife beneficial landscaping".

Object

Representation ID: 25950

Received: 12/03/2019

Respondent: Environment Agency

The policy should include reference to Biodiversity Net Gain. The Defra 25 Year Plan (2018), available here https://www.gov.uk/government/publications/25-year-environment-plan, includes a policy to embed the 'environmental net gain' principle
for development. This will enable development without increasing overall burdens on developers. The planning system should provide biodiversity net gains where possible as required in NPPF paragraph 170.

Object

Representation ID: 25951

Received: 12/03/2019

Respondent: Environment Agency

Paragraph 9.8.7 could be enhanced by making reference to the river corridor, preferably in a standalone paragraph, describing how new development along the river corridor will be required to enhance the biodiversity value of the riparian zone and ensure water quality is protected and enhanced.

Object

Representation ID: 26139

Received: 08/03/2019

Respondent: Suffolk Wildlife Trust

Paragraph 9.8.2 makes reference to the Conservation of Habitats and Species Regulations, it should be noted that these regulations were updated in 2017 and references to them should be amended accordingly.