Preferred Options Core Strategy and Policies Development Plan Document (DPD) Review

Object

Representation ID: 25746

Received: 12/03/2019

Respondent: Natural England

Support the Plan's vision to protect and enhance the natural environment

The plan should take a strategic approach to the protection and enhancement of the natural environment, in accordance with paragraphs 170 and 174 of the NPPF and the Defra 25 Year Environment Plan (YEP), including providing a net gain for biodiversity, considering opportunities to enhance and improve connectivity. Where relevant there should be linkages with the Biodiversity Action Plan, Local Nature Partnership, National Park/Area of Outstanding Natural Beauty Management Plans, Rights of Way Improvement Plans and Green Infrastructure Strategies, Nature Recovery Network (amend as appropriate to the local area).

Object

Representation ID: 25747

Received: 12/03/2019

Respondent: Natural England

We advise that the potential impacts of this policy are assessed to determine the suitability of the existing Recreational Disturbance Avoidance and Mitigation Strategy (RAMS) in mitigating the effects of increased recreational disturbance to Suffolk's coastal, estuarine and heathland European sites as a result of strategic growth. The effects of growth on other statutorily designated sites, including Sites of Special Scientific Interest (SSSIs), should also be assessed and measures to address adverse impacts identified, applying the mitigation hierarchy in accordance with paragraph 175 of the NPPF.

Object

Representation ID: 25748

Received: 12/03/2019

Respondent: Natural England

Increased traffic, the construction of new roads and the upgrading of existing roads can negatively affect designated sites due to air quality impacts. We recommend that potential impacts to vulnerable sites are assessed using traffic projections and the 200m distance criterion followed by local Air Quality modelling where required.

Large infrastructure opportunities to secure net gains for biodiversity and wider
environmental gains (HRA, page 9), please include within the supportive text of the
policy. Policy requirements for large infrastructure projects to deliver measurable biodiversity net gain, in accordance with NPPF and Defra 25 YEP, should be included with relevant policies.

Object

Representation ID: 25749

Received: 12/03/2019

Respondent: Natural England

Natural England supports and welcomes the Council's commitment to a cross boundary approach to recreational disturbance. We advise that the supplementary planning document is assessed to ensure that the delivery of strategic projects is sufficient to mitigate additional impacts.

Object

Representation ID: 25751

Received: 12/03/2019

Respondent: Natural England

We welcome an ecological network approach to connect fragmented wildlife habitat, including designated sites. We agree that there are opportunities in development to conserve and enhance biodiversity through net gain. We advise that biodiversity net gain is incorporated into to Policy CS4 to enable delivery through development. This requirement should be proportionate to the size of the development and not limited to large applications. It is recommended that policy is founded on an evidence base that includes mapping assets and identifying areas for creation (incorporated in GI strategy and SPD's).

Object

Representation ID: 25753

Received: 12/03/2019

Respondent: Natural England

The Local Plan should give appropriate weight to the roles performed by the area's soils. These should be valued as a finite multi-functional resource which underpins our wellbeing and prosperity. Decisions about development should take full account of the impact on soils, their intrinsic character and the sustainability of the many ecosystem services they deliver.

The plan should safeguard the long term capability of best and most versatile agricultural land (Grades 1, 2 and 3a in the Agricultural Land Classification) as a resource for the future in line with National Planning Policy Framework paragraph 170.

Object

Representation ID: 25757

Received: 12/03/2019

Respondent: Natural England

The scale and design of onsite green space should be assessed to ensure it is sufficient to absorb routine recreational activities. In addition, we advise that onsite accessible space is designed to facilitate biodiversity and support wildlife. Ipswich garden suburb presents a great opportunity for biodiversity net gain and we propose that this is incorporated into Policy CS10.

We support policy text that states development proposals will demonstrate accordance with the SPD and positively facilitate the development of other phases of the Ipswich Garden Suburb area.

Object

Representation ID: 25758

Received: 12/03/2019

Respondent: Natural England

expect the plan to address the impacts of air quality on the natural environment. It should address the traffic impacts associated with new development, particularly where this impacts on European sites and SSSIs.

One of the main issues which should be considered in the plan and the SA/HRA are proposals which are likely to generate additional nitrogen emissions as a result of increased traffic generation, which can be damaging to the natural environment.

Object

Representation ID: 25759

Received: 12/03/2019

Respondent: Natural England

The effects on local roads in the vicinity of any proposed development on nearby designated nature conservation sites, and the impacts on vulnerable sites from air quality effects on the wider road network should be assessed using traffic projections and the 200m distance criterion followed by local Air Quality modelling where required. The designated sites at risk from local impacts are those within 200m of a road with increased traffic, which feature habitats that are vulnerable to nitrogen deposition/acidification.

Object

Representation ID: 25762

Received: 12/03/2019

Respondent: Natural England

Support this policy. recommends that large developments include green space that is proportionate to its scale to minimise any predicted increase in recreational pressure to designated sites, by containing the majority of recreation within and around the developed site. The Suitable Accessible Natural Green Space (SANGS) guidance can be helpful in designing this; it should be noted that this document is specific to the SANGS creation for the Thames Basin Heaths, although the broad principles are more widely applicable. Green infrastructure design should seek to achieve the Natural England Accessible Natural Greenspace Standards. Recommend six features for provision.