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

Object

Representation ID: 25909

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 (d) should be further strengthened by amending the wording to "Supporting and securely funding the Greenways Project".

Object

Representation ID: 25911

Received: 12/03/2019

Respondent: Environment Agency

It is welcoming to see reference to the Water Framework Directive (WFD) in paragraph 8.71 however, detail is sparse. To improve the wording of this paragraph the Local Plan should identify the two key objectives of WFD: no deterioration of waterbodies and ultimately improving all waterbodies to good status by 2027. These
objectives are key requirements of WFD. This could be further enhanced if the Local Plan included WFD baseline information on the local River Basin Management Plan (RBMP), specifically relating to the status of WFD waterbodies surrounding Ipswich Borough.

Object

Representation ID: 25913

Received: 12/03/2019

Respondent: Environment Agency

Water Framework Directive (WFD) in paragraph 8.71, it would be useful to highlight the number of waterbodies within the borough failing WFD 'ecological status or potential' and 'chemical status'. It is important to note that no development, either individually or cumulatively can cause deterioration in WFD status. All development should seek to enhance water quality reaching waterbodies in Ipswich by use of appropriate SuDS techniques that include pollution prevention and control measures.

Object

Representation ID: 25918

Received: 12/03/2019

Respondent: Environment Agency

Policy CS11 Gypsy and Traveller accommodation. We are in agreeance with the policy- Caravans, mobile homes and park homes intended for permanent residential use are classed as 'Highly Vulnerable' as defined in Table 2: Flood Risk Vulnerability Classification of the Planning Practice Guidance are not permitted in Flood Zone 3 and require the exception test in Flood Zone 2. These developments are very difficult to make safe through raised flood levels. Therefore, we consider that the requirement for gypsy and traveller sites to be free from flood risk should be maintained in any new policy.

Support

Representation ID: 25920

Received: 12/03/2019

Respondent: Environment Agency

Policy CS11 refers to Gypsy and Traveller accommodation. We are in agreeance with the policy. In terms of contamination, we are pleased to see that the policy states that the site should be free from significant contamination which whilst broad, does cover any concerns we may have.

Object

Representation ID: 25921

Received: 12/03/2019

Respondent: Environment Agency

Policy CS16 - Green Infrastructure, Sport and Recreation. Paragraph 8.189 refers to Natural Flood Management. The wording of this paragraph could be further enhanced by incorporating reference to reducing flooding by working with natural process, reconnecting watercourses with flood plains to enhance flood storage in times of need and taking opportunities to restore watercourses to a naturalised state. This should be considered and incorporated into developments whenever opportunities arise. Such measures can provide benefits in terms of biodiversity, amenity, health and wellbeing and should be incorporate into the scheme design from the outset.

Support

Representation ID: 25922

Received: 12/03/2019

Respondent: Environment Agency

We are pleased to see the inclusion of Policy CS16 - Green Infrastructure, Sport and Recreation. We welcome that paragraph 8.189 also suggests low lying areas are identified for flood storage. It could be good to include this within the SFRA.

Object

Representation ID: 25928

Received: 12/03/2019

Respondent: Environment Agency

EA suggests inclusion of a section of text on "blue corridors". Blue corridors 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 recreation. The recreation activities normally relate to walk or cycle routes alongside the River. IBC have tried to establish public access along the urban river Gipping to allow canoe and kayak access as part of voluntary agreements. The policy/plan could be enhanced by including reference to maintaining public access to the water itself.

Object

Representation ID: 25934

Received: 12/03/2019

Respondent: Environment Agency

The following site allocations have been identified as potentially important to the feasibility of establishing public access along the urban river Gipping to allow canoe and kayak access to the river Gipping:
* IP003 * IP015 * IP031 * IP037 * IP047 * IP083
* IP105 * IP119 * IP120b * IP132 * IP136 * IP147
* IP149 * IP188 * IP346
Consideration should be made when developing these sites to ensure that this promotes public access to the River Gipping.

Object

Representation ID: 25936

Received: 12/03/2019

Respondent: Environment Agency

Policy CS17 - Delivering Infrastructure. The policy refers to the Community Infrastructure Levy (CIL) and outlines the types of infrastructure that can be secured or financed from new developments. This includes, but is not limited to, Environment and Conservation as well as Sport and Recreation. Norwich Railway line sluice on the River Gipping had its gates removed a number of years ago. The concrete structure remains and requires removal. This policy could be used to help fund the structures removal to ensure public access to the river and provide environmental improvements as outlined in our response to policy CS16.