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Issues and Options for the Ipswich Local Plan Review

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Comment

Issues and Options for the Ipswich Local Plan Review

Question 17:

Representation ID: 24645

Received: 30/10/2017

Respondent: RSPB

Agent: RSPB

Representation Summary:

Any actions taken on this matter needs to pay full consideration to the Green Infrastructure network and assess how any decisions may impact upon it.

Full text:

Any actions taken on this matter needs to pay full consideration to the Green Infrastructure network and assess how any decisions may impact upon it.

Comment

Issues and Options for the Ipswich Local Plan Review

Question 20:

Representation ID: 24646

Received: 30/10/2017

Respondent: RSPB

Agent: RSPB

Representation Summary:

It is not only essential that the protection of green space is upheld, but also that the overall tone of such a question should be about enhancing these areas. Evidence shows that those who live within 500 metres of accessible green space are 24% more likely to meet recommended health levels of physical exercise.

Full text:

It is not only essential that the protection of green space is upheld, but also that the overall tone of such a question should be about enhancing these areas. Evidence shows that those who live within 500 metres of accessible green space are 24% more likely to meet recommended health levels of physical exercise.

Comment

Issues and Options for the Ipswich Local Plan Review

Question 2:

Representation ID: 24647

Received: 30/10/2017

Respondent: RSPB

Agent: RSPB

Representation Summary:

A network of wildlife-rich sites around and through the borough recognised through the highly commendable Ipswich Wildlife Network.

Full text:

A network of wildlife-rich sites from internationally designated Special Protection Areas (SPAs) and Ramsar sites; nationally designated Sites of Special Scientific Interest (SSSIs) and at a local level - County Wildlife Sites (CWS), Roadside Nature Reserves (RNRs), priority species and habitats.
The conservation and enhancement of these will ensure that the Local Plan will meet its requirements laid down by the NPPF.
The Ipswich Wildlife Network produced by the Council, Greenways Project and Ipswich Wildlife Group is an excellent example of positive partnership working which recognises the importance of the existing ecological network in the town and identifies what is needed to protect and, more importantly, enhance it.
We would endorse a similar approach being adopted across the IHMA (as the Council aspires to in their identification of Environmental Issues) and would be happy to assist the Council(s) in developing such a network.

Comment

Issues and Options for the Ipswich Local Plan Review

Question 33:

Representation ID: 24648

Received: 30/10/2017

Respondent: RSPB

Agent: RSPB

Representation Summary:

The RSPB welcomes IBC's commitment to the Recreational Avoidance and Mitigation Strategy (RAMS) and to develop a "Green Rim" around Ipswich to alleviate recreational pressure on sensitive sites (SPAs).

New developments should incorporate wildlife-rich appropriately accessible green space paying particular attention to the needs of dog-walkers and recognizing the wider benefits of protecting and enhancing sites for priority species and habitats. There are wider benefits to residents health and wellbeing to be had too.

We refer IBC to https://www.rspb.org.uk/our-work/conservation/projects/kingsbrook-housing as an exemplar case study.

We support partnership working to deliver the above.

Full text:

We recommend that it is specified in the pre-submission Local Plan that the frameworks and masterplans for each development must include clear and evidenced strategies to avoid increasing recreational pressure on internationally designated wildlife sites, in line with duties on the Council to conserve biodiversity.

We welcome the Councils' commitment to the strategic mitigation plan currently under development for recreational impacts of new housing developments on internationally-designated sites, known as the Recreational Avoidance and Mitigation Strategy (RAMS). Where a development is likely to give rise to a significant effect on an internationally designated site and it is possible to mitigate this effect, developers should be required to contribute to the RAMS, to ensure that mitigation is strategic rather than piecemeal, and give confidence that mitigation measures can be delivered. We recommend that these requirements are specified within an appropriate policy in the Local Plan.

In order to understand whether measures to protect sensitive sites are being effective, there needs to have been a baseline of monitoring conducted to understand the extent and type of pressure these sites face. Information from this monitoring can then be used to inform the RAMS, which from experience elsewhere in the UK, we know will require paid wardens/rangers to be employed to raise awareness of the importance of coastal sites and promote positive behaviours amongst local communities and visitors alike.

The RSPB would welcome working with SCDC, IBC and other parties, e.g. Suffolk Wildlife Trust and The Greenways Project in helping to maximise the over-arching benefits to biodiversity, residents and visitors alike of such a strategy.

Alongside the RAMS, we consider that the key means to avoid increasing pressure on designated sites will be through provision of high quality green space close to people's homes and at a scale that is appropriate to the level of planned growth. This should be wildlife rich green space, again in line with the Council's biodiversity duties. Furthermore, access to such spaces will have wider societal benefits by contributing to the health and wellbeing of residents, e.g. for dog-walking, jogging or wildlife-watching.

The RSPB welcomes the intention to deliver a "Green Rim" around Ipswich as part of IBC's strategy to alleviate recreational pressure on sensitive sites and we support the stated intention to co-operate with neighbouring planning authorities on this matter.

All developments should be nature friendly, with homes for nature integrated with homes for people during the design phase. Providing access to high quality greenspace on people's doorsteps will help to alleviate recreational pressure on important wildlife sites from the new developments and promote a connection to nature for residents.

With the planned scale of development there will be many opportunities to bring nature closer to people at the local scale. An example of how to develop nature-friendly homes is the Kingsbrook Barratt Homes development at Aylesbury, Oxfordshire where RSPB has worked in partnership with Barratt Homes PLC to design housing that benefits people and nature (https://ww2.rspb.org.uk/our-work/conservation/projects/kingsbrook-housing). Further details on our experience working with Barratt Homes PLC and Aylesbury Vale District Council to set a positive example of nature-friendly and wildlife rich development, which we would like to see as the new common standard is provided in Annex 1.

Offering the opportunity for increased connection to nature within the development, through accessible and wildlife-rich green space and wildlife friendly gardens benefits both the natural environment and maximises the health and well-being benefits for residents. The benefits of nature on people's mental health are widely reported within scientific literature; however, recently it has become apparent that the quality of the natural environment may be more important than the quantity of it. People are twice as likely to report low psychological distress when living close to quality green space compared with those living near low quality green space [Francis, J., Wood, L.J., Knuiman, M., and Giles-Corti, B. (2012) Quality or Quantity? Exploring the relationship between Public Open Space attributes and mental health in Perth, Western Australia. Social Science and Medicine 74: 1570 - 1577.].

Therefore, it is important not only to plan for easy access to green spaces in our living environment but also to improve the quality of these green spaces - incorporating greater levels of biodiversity in our green spaces could be one way to achieve this.

Natural England have established methods to calculate how much green space will be required in relation to the level of recreational need, known as the Accessible Natural Greenspace Standard (http://publications.naturalengland.org.uk/category/47004). We recommend these methods provide the basis of calculating necessary greenspace for new developments.

The RSPB would be grateful for the opportunity to provide further advice on these matters during preparation of the pre-submission version of the Local Plan.

One of the main pressures identified on designated sites is dogs off-lead. New developments should therefore be managed with dog-walkers in mind and have accessible green space within easy walking distance. The average dog-walk is 2.7km and a dog-owner will only walk around 4-500m to begin exercising their dog, otherwise they are likely to drive to a site to do so. This in itself, adds unnecessary traffic to roads and will increase air pollution and heighten the risk of sensitive sites being disturbed.

Hampshire County Council have produced a guidance document called Planning for dog ownership in new developments: reducing conflict - adding value. Access and greenspace design guidance for planners and developers (March 2013) which provides greater detail.

Comment

Issues and Options for the Ipswich Local Plan Review

Question 37:

Representation ID: 24649

Received: 30/10/2017

Respondent: RSPB

Agent: RSPB

Representation Summary:

No. Any proposal to reallocate countryside as housing, will first need to map the presence of any priority habitats and species.
Mitigation for certain farmland bird species, e.g. skylark is likely to be impractical within developments so will need to be secured off-site.

Full text:

No.
An integrated landscape approach to improve ecological networks is the core means to conserve our wildlife. However, this approach will not be sufficient to achieve the recovery of all species, and in some cases, it will need to be complemented by specific tailored actions. As highlighted in Professor John Lawton's 2010 report "Making Space for Nature", many habitats such as hedgerows, meadows, heathlands, woodlands, sand dunes, wetlands and flower rich field margins do not fall within protected sites.
Any move to reallocate countryside as housing must first be monitored to map any priority habitats and species present. In terms of bird species, monitoring should include the suite of typical farmland birds such as Yellowhammer, Skylark and Linnet, but this may also include those associated with scrub, such as Turtle Dove and Nightingales. Hedgerows may provide important wildlife corridors for protected species such as dormice and bats.
It is important to note that providing mitigation for these species within new developments is normally impractical due to their particular ecological requirements, so any mitigation will need to be established off-site in the long-term.

Comment

Issues and Options for the Ipswich Local Plan Review

Question 38:

Representation ID: 24678

Received: 30/10/2017

Respondent: RSPB

Agent: RSPB

Representation Summary:

The RSPB considers that open space should not be re-allocated to housing.
For all ages, "access to green spaces is associated with better mental and physical health across socioeconomic groups" (Healthy lives, healthy people: our strategy for public health in England' - Dept Health White Paper, November 2010; paragraph #3.36)
We commend the Council and its partners for mapping the Ipswich Wildlife Network and endorse that Core Strategy policy DM31 sets out that development proposals will be required to have regard to existing habitat features and the wildlife corridor function, through their design and layout, and achieve net biodiversity gains.

Full text:

No.
For all ages, "access to green spaces is associated with better mental and physical health across socioeconomic groups" (Healthy lives, healthy people: our strategy for public health in England' - Dept Health White Paper, November 2010; paragraph #3.36)
We would urge the Council to include Natural England's Accessible Natural Green Space Standards (currently under review) or Design for Play, which explains how good play space can give children and young people the freedom to play creatively, while allowing them to experience risk, challenge and excitement.
We commend the Council and its partners for its positive approach in mapping the Ipswich Wildlife Network and endorse that policy DM31 of the Core Strategy sets out that development proposals will be required to have regard to existing habitat features and the wildlife corridor function, through their design and layout, and achieve net biodiversity gains.
Evidence in England shows that proximity to green space can add £2000 to the capital value of houses, emphasising the economic and social benefits of such amenities.

Comment

Issues and Options for the Ipswich Local Plan Review

Question 74:

Representation ID: 24687

Received: 30/10/2017

Respondent: RSPB

Agent: RSPB

Representation Summary:

The RSPB fully supports a co-ordinated, planned approach to the implementation of SuDS.
SuDS need to be incorporated at the earliest stage of the planning process, be on or near the land surface and delivered in broad partnership to the satisfaction of the end user (residents).
Their effectiveness should also be monitored.
In conjunction with the Wildfowl and Wetlands Trust (WWT), we have produced a report on this subject (Graham/Day/Bray/Mackenzie - Sustainable Drainage Systems - Maximising the potential for people and wildlife: A guide for local authorities and developers).

Full text:

The RSPB welcomes the Council setting out such a clear commitment to Sustainable Drainage Systems (SuDS), to which we are strong advocates.
In conjunction with the Wildfowl and Wetlands Trust (WWT), we have produced a report on this subject (Graham/Day/Bray/Mackenzie - Sustainable Drainage Systems - Maximising the potential for people and wildlife: A guide for local authorities and developers).
A report produced by Environmental Policy Consulting in January 2017 for the Welsh Government, highlights the following advantages of SuDS:
a. SuDS need to be planned at the earliest stage of the planning process and integrated with general landscape design and maintenance;
b. SuDS on or near the land surface are far more cost-effective than below-ground proprietary systems;
c. Working in the broadest possible partnership offers the greatest potential to maximise benefits and lever additional funding; and
d. The significant role of 'champions' in obtaining 'buy-in', managing relationships using voluntary agreements, and in promoting successful delivery and continuing functioning of SuDS.

Comment

Issues and Options for the Ipswich Local Plan Review

Question 1:

Representation ID: 24691

Received: 30/10/2017

Respondent: RSPB

Agent: RSPB

Representation Summary:

The RSPB welcomes that the Council recognises the network of wildlife-rich sites, species and habitats; the need to invest in renewable energy; recognition of the need to tackle the threats posed by climate change and the foresight to extend and enhance the Green Infrastructure network across the whole Ipswich Housing Market Area (IHMA).
The critical element is an overall commitment for enhancing biodiversity and this should be at the forefront as an environmental issue in order to be consistent with the national planning policy framework (NPPF).

Full text:

The RSPB welcomes that the Council recognises the network of wildlife-rich sites, species and habitats; the need to invest in renewable energy; recognition of the need to tackle the threats posed by climate change and the foresight to extend and enhance the Green Infrastructure network across the whole Ipswich Housing Market Area (IHMA).
The critical element is an overall commitment for enhancing biodiversity and this should be at the forefront as an environmental issue in order to be consistent with the national planning policy framework (NPPF).

Comment

Issues and Options for the Ipswich Local Plan Review

Question 75:

Representation ID: 24693

Received: 30/10/2017

Respondent: RSPB

Agent: RSPB

Representation Summary:

This report (Environmental Policy Consulting - Sustainable Drainage Systems on new developments:
Analysis of evidence including costs and benefits of SuDS construction and adoption, Final Report For the Welsh Government January 2017) sets out the significant economic, social and environmental benefits of SuDS.
Including:
* capital cost saving of £9000/home
* Improve water quality and protect drinking water resources
* Limit flows entering system and therefore maximise network capacity
* Improve health and wellbeing
* Help manage air quality
* Increase property value
* Enhance biodiversity
* Provide education
* Improve thermal comfort
* Provide amenity and recreation


Full text:

The report produced for the Welsh Government by Environmental Policy Consulting (January 2017) highlights the positive breadth of SuDS economically, socially and environmentally:
1. Use of SuDS in Wales alone, could save up to £9,000 in capital cost alone per new home. Based on the Objectively Assessed Housing Need (OAN) for the IHMA of 11,420 new dwellings by 2036, by simple translation, this would represent a saving of just over £100 million within the IHMA.
2. use of SuDS could generate benefits of well over £300 per household per year on large developments.
3. For the 110,000 homes planned for Wales by 2021, use of SuDS could save Wales nearly £1 billion in capital construction costs and generate benefits of over £20 million per year.
From Table 6 (page 41) of the report: Evidence on the benefits of SuDS include
* Improve water quality and protect drinking water resources
* Limit flows entering system and therefore maximise network capacity
* Improve health and wellbeing
* Help manage air quality
* Increase property value
* Enhance biodiversity
* Provide education
* Improve thermal comfort
* Provide amenity and recreation
The report also details ten Case Studies in the appendices which we would ask the Council to review and take in to consideration.

Comment

Issues and Options for the Ipswich Local Plan Review

Question 34:

Representation ID: 24740

Received: 30/10/2017

Respondent: RSPB

Agent: RSPB

Representation Summary:

Policy DM6 - Additional line k) to incorporate integrated swift-bricks
Policy DM10 - Re-word as Protection and Enhancement of trees and hedgerows
Policy DM28 - We question the tone of this policy. NPPF sets out that open spaces should be protected and enhanced.
Policy DM31 - needs to include SPAs and SSSIs

Full text:

Policy DM6 - Tall buildings
Additional line k) to incorporate integrated swift-bricks
Integrated swift-bricks are low-cost (in the region of £20) and will help deliver on the urgent need for lost nest-spaces for this species which has undergone a 51% decline since the 1990s.
Policy DM10 - this policy should be re-worded as Protection and ENHANCEMENT of trees and hedgerows in order to be consistent with the NPPF.
Policy DM28 - the tone of this policy is wrong. To be consistent with the NPPF, it should look to preserve and enhance areas of open space.
Policy DM31 - this should explicitly identify the Stour and Orwell estuaries Special Protection Area (SPA) and the Deben Estuary SPA, plus any Sites of Special Scientific Interest (SSSIs) within or near to the IBC boundary.

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