Issues and Options for the Ipswich Local Plan Review

Comment

Representation ID: 25174

Received: 30/10/2017

Respondent: Environment Agency

Although Ipswich will soon benefit from the new Ipswich Tidal Flood Barrier, there remains residual tidal flood risk from barrier failure as well as fluvial flood risk from the River Gipping and neither should be overlooked. There is no mention of the Water Framework Directive (WFD), and the requirements and obligations laid out in the Anglian RBMP. This links to water quality, but also ecology and amenity. Overall, the plan should give greater consideration to the management and enhancement of the water environment.
The existing SFRA does consider the new Ipswich Tidal Flood Barrier and associated works, due for completion by April 2018. It is unclear if there is an intention to undertake a new SFRA, if so we would recommend discussion with ourselves with regard to this work. We are currently preparing new flood models for the River Gipping and the coast and estuaries. These are unlikely to be available until post-submission so they cannot be included in any new SFRA or the Local Plan, but they may need to be taken into account by developers in their FRAs. The Local Plan must also have regard to the Anglian river basin district River Basin Management Plan (RBMP) 2015. The RBMP is referred to in the SA Scoping Report, but it should help underpin and inform policies and approach in the plan. It is not clear if this is the case to date.

Comment

Representation ID: 25176

Received: 30/10/2017

Respondent: Environment Agency

Options 4 and 6 propose Framlingham as a location for 6% and 4% of housing respectively. The sewage treatment works is over capacity already, so it is important to note that further capacity will be required to support growth. The Sustainability Appraisal Scoping Report identifies the need to invest in sewage treatment capacity with regard to an increase in population. The Shared Evidence Base section and SA Scoping Report refer to a water cycle study, and the issue of available foul water treatment capacity should help inform the location and timing of development.
When deciding where to locate growth, flood risk is an essential consideration. The SFRA must be used as an evidence base to ensure that development is sequentially sited in areas with the lowest probability of flooding as defined by the Planning Practice Guidance.

Comment

Representation ID: 25177

Received: 30/10/2017

Respondent: Environment Agency

We would wish to see Local Plans for Ipswich and Suffolk Coastal that take a holistic approach to sustainable development that benefits people, the environment and the economy. Open landscape is recognised in this plan as an opportunity to create habitat and reduce flood risk, but the provision of multifunctional open space also has the potential to improve a community's physical health and mental wellbeing, and increase the monetary value of new development. The wider benefits of ecosystem services should be recognised, and the Plan should seek to both protect and enhance the natural environment.

Comment

Representation ID: 25178

Received: 30/10/2017

Respondent: Environment Agency

If open space sites are to be reallocated to housing, it is vital that the social, environmental and economic value is not lost. Instead, new housing development can be used as an opportunity to make local areas of open space more accessible. A network of sites is preferable for urban biodiversity, and any reduction will put additional pressure on sites that are more sensitive to recreational disturbance such as the Orwell Estuary SSSI.

Comment

Representation ID: 25179

Received: 30/10/2017

Respondent: Environment Agency

When allocating additional permanent pitches for Gypsies and Travellers, we support the existing policy CS11, which requires under b.iii. for the site to be 'free from flood risk'. Caravans, mobile homes and park homes intended for permanent residential use are classed as 'highly vulnerable' so are not permitted in Flood Zone 3, require the exception test in Flood Zone 2, and are very difficult to make safe through raised flood levels. Therefore, we consider that this requirement for Gypsy and Traveller sites to be free from flood risk should be maintained in any new policy.

Comment

Representation ID: 25180

Received: 30/10/2017

Respondent: Environment Agency

No mention is made of the Ipswich Tidal Flood Barrier and associated flood defences or to foul drainage capacity in Ipswich. Both topics are raised in the Sustainability Appraisal Scoping Report and should also be included here. If a Community Infrastructure Levy is to be adopted, we would welcome contributions towards flood risk infrastructure such as the future maintenance of the tidal barrier and existing tidal and fluvial defences. Also, the River Gipping and Orwell Estuary are overlooked in the plan. The Gipping is a neglected asset. Include proposals to enhance its visual and ecological quality and maintain water quality.

Comment

Representation ID: 25181

Received: 30/10/2017

Respondent: Environment Agency

If a Community Infrastructure Levy is to be adopted, we would welcome contributions towards flood risk infrastructure such as the future maintenance of the tidal barrier and existing tidal and fluvial defences.

Comment

Representation ID: 25182

Received: 30/10/2017

Respondent: Environment Agency

The Plan refers to SuDS as a means of surface water drainage. IBC should liaise with Suffolk County Council (as Lead Local Flood Authority) on potential opportunities to reduce and manage surface water flooding. We support the use of SuDS to help to prevent the pollution of groundwater and surface water, provide aquifer recharge and to provide ecological and amenity benefit, in addition to managing flood risk. It should also be ensured that appropriate measures for maintaining SuDS are put in place. SuDS should be integrated into schemes at an early stage and designed to provide maximum benefits without causing adverse impacts. Deep infiltration systems should be a last resort option for disposal of surface water. Appropriate pollution treatment steps must be in place (CIRIA C753).

Comment

Representation ID: 25184

Received: 30/10/2017

Respondent: Environment Agency

We support the consideration on water efficiency for new development. The Environment Agency 'water stressed areas - final classification' report, July 2013, identifies the entire area as being under 'serious stress' and over time pressures from changing weather and population growth are likely to increase. As well as supporting the natural environment, water resources are critical to sustainable economic growth and housing development.

Comment

Representation ID: 25185

Received: 30/10/2017

Respondent: Environment Agency

This section could expand upon the use of multifunctional open spaces to contribute towards sport and leisure provision. These spaces provide playing fields and amenity space, which improve the physical health and mental wellbeing of the community. The Plan should take an integrated approach to combine the provision of sports and leisure with open space and biodiversity to best benefit people and wildlife.