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

Support

Representation ID: 25754

Received: 12/03/2019

Respondent: Environment Agency

We welcome reference to the local Water Cycle Study (WCS) and the local surface water management plan within paragraph 8.41 of the Local Plan. The WCS will serve as an evidence base to support the local plan and should suggest policies and measures to enable the delivery of all proposed development.

Object

Representation ID: 25755

Received: 12/03/2019

Respondent: Environment Agency

Therefore, we would expect to see a summary of the findings and recommendations of the WCS and surface water management plan within the local plan. Any areas of concern in terms of waste water and sewerage infrastructure provisions should be highlighted and details of how development will be dealt with sustainably within the Borough provided in accordance with NPPF paragraph 20 section b. It should however be noted that the Haven Gateway Water Cycle Study is now 10 years old, this should be taken into consideration when referring to the WCS.

Object

Representation ID: 25756

Received: 12/03/2019

Respondent: Environment Agency

If the Water Cycle Study is updated, this should be referred to when the local plan is updated. The paragraph could be enhanced by referencing that development should be phased in line with infrastructure upgrade timescales, thus ensuring adequate waste and water infrastructure is in place to accommodate the demands from additional growth in the borough.

Object

Representation ID: 25901

Received: 12/03/2019

Respondent: Environment Agency

We would like paragraph 8.43 to include some text about the benefits of trees for rivers. Trees are important in helping to keep rivers cool and therefore improving the state of the river for biodiversity. By providing shade, trees are able to moderate the extremes in water temperature which can be detrimental to fish spawning. Their underwater root systems provide valuable habitat to fish and invertebrates whilst stabilising the banks. Shading can also be helpful in the control of aquatic vegetation and well as bringing benefits for people.

Object

Representation ID: 25902

Received: 12/03/2019

Respondent: Environment Agency

Green spaces and functioning ecosystems are referenced in paragraph 8.44. This paragraph could be enhanced by specifically referring to blue corridors (such as the River Gipping) here too. Blue corridors promote the idea of 'making space for water' and can involve setting back urban development from watercourses, overland flow paths and ponding areas creating a mosaic of urban corridors designed to facilitate natural hydrological processes whilst minimising urban flooding, enhancing biodiversity and improving access to recreation.

Object

Representation ID: 25903

Received: 12/03/2019

Respondent: Environment Agency

We are pleased to see the inclusion of policy CS2 - The Location and Nature of Development. Point (g) of the policy should be strengthened include reference to blue corridors to state "dispersing open space based (non-commercial) leisure uses throughout the town with preferred linkages to ecological networks and/or green and blue corridors and protecting the countryside from inappropriate development".

Object

Representation ID: 25904

Received: 12/03/2019

Respondent: Environment Agency

Policy CS4 - Protecting our Assets outlines how the council will conserve and promote the enjoyment of the historic environment. We would suggest that another point is added to this policy saying that "Preventing the spread on non-native invasive species by ensuring that an appropriate biosecurity protocol is adopted".

Object

Representation ID: 25905

Received: 12/03/2019

Respondent: Environment Agency

Policy CS4 - Protecting our Assets outlines how the council will conserve and promote the enjoyment of the historic environment.
Point (a) should be strengthened by changing the wording of this to read "Applying full protection to international, national and local designated sites and protected and priority species".

Object

Representation ID: 25906

Received: 12/03/2019

Respondent: Environment Agency

Policy CS4 - Protecting our Assets outlines how the council will conserve and promote the enjoyment of the historic environment. Point (c) should also be strengthened by amending its wording to "Preventing the loss of ancient woodland and ancient or veteran trees in accordance with national policy and requiring new development to plant the veteran trees of the future using appropriate native species of local provenance".

Object

Representation ID: 25907

Received: 12/03/2019

Respondent: Environment Agency

Policy CS4 - Protecting our Assets outlines how the council will conserve and promote the enjoyment of the historic environment. paragraph 8.75 should also be amended accordingly to state that "Ancient and semi-natural woodlands and veteran trees are irreplaceable habitats of high biodiversity value and must be protected from development that would result in damage to or loss of any of these features"