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

Support

Representation ID: 25734

Received: 12/03/2019

Respondent: Environment Agency

Paragraph 6.13 states that sites alongside the river in much of central Ipswich reside within Flood Zones 2 and 3. We are pleased that the paragraph outlines the process involved when siting development within these flood zones.

Object

Representation ID: 25735

Received: 12/03/2019

Respondent: Environment Agency

This paragraph (Para 6.13) should also include reference to safe refuge. Safe refuge should be provided to any development within these zones (Flood Zones 2 and 3) to ensure they remain safe in times of flood from residual flood risk (i.e. from overtopping or breach).

Object

Representation ID: 25737

Received: 12/03/2019

Respondent: Environment Agency

In addition, the paragraph (6.13) also makes brief reference to SuDS. The paragraph should make clear that the use of infiltration SuDS may not be suitable at sites where contamination is present. Alternative SuDS features should be used in these circumstances.

Object

Representation ID: 25740

Received: 12/03/2019

Respondent: Environment Agency

The Ipswich Flood Defence Strategy (IFDMS) is referred to in Paragraph 6.15 and Paragraph 6.16. This section also outlines the work that began in 2008 to replace and raise the height of the floodgates in the Wet Dock lock. The Ipswich Tidal Defence Barrier is now operational and as such this should be specifically referenced.

Object

Representation ID: 25741

Received: 12/03/2019

Respondent: Environment Agency

We have also updated our coastal and estuary modelling in Ipswich. This includes the new barrier and it supersedes the modelling used in the SFRA and SPD. The
existing SFRA refers to PPS25 which has now been replaced by the National Planning Policy Framework (NPPF) 2018 and is no longer based on the most up to date evidence. The SFRA suggests a framework for safe development which is detailed in the Flood Risk SPD (September 2013). We would suggest that the SPD could also be updated following the production of a revised SFRA.

Object

Representation ID: 25743

Received: 12/03/2019

Respondent: Environment Agency

We would suggest that the SPD could also be updated following the production of a revised SFRA. Section 7.3.4 of the SPD outlines the requirement for consideration of residual risk, specifically requiring temporary refuge above 0.1% annual probability flood level with climate change. Now the barrier is operational, if you choose to update your SFRA, you may wish to consider reviewing your refuge requirement. We are currently in the process of updating our River Gipping fluvial flood modelling which should be also considered.

Object

Representation ID: 25744

Received: 12/03/2019

Respondent: Environment Agency

If no update to the SFRA is carried out, then refuge capability should be judged on the worst case of the existing breach modelling (from the old SFRA/SPD) or the current extreme tide (with climate change) overtopping of the system from our new coastal modelling.

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.