Object

Representation ID: 25939

Received: 12/03/2019

Respondent: Environment Agency

Paragraph 8.198 refers to appendix 4 which lists the types of infrastructure referred to within Policy CS17. We would expect to see wastewater/sewerage infrastructure listed in the utilities section because it is likely that some improvements will be required in order to enable or facilitate growth. The bullet point names "water" could be further expanded to say "water - potable and wastewater supply".

Object

Representation ID: 25940

Received: 12/03/2019

Respondent: Environment Agency

Paragraph 8.199 highlights the pressure that growth and development put on existing infrastructure and correctly identifies that there will be a need to upgrade existing infrastructure within the borough. This paragraph could be strengthened to reflect the need to ensure growth and development is phased in line with these upgrades to infrastructure, particularly water utilities infrastructure.

Support

Representation ID: 25941

Received: 12/03/2019

Respondent: Environment Agency

We welcome the inclusion of policy DM1 - Sustainable Construction. We fully support paragraph 9.1.5 which states the East Anglian area is identified as an area of severe water stress and that lowering water demand is identified as one of a range of measures to balance supply and demand in the Anglian Water Resources Management Plan 2015. We are pleased to see inclusion of requiring residential development being required to meet water efficiency standards of 110 litres of water per person per day.

Object

Representation ID: 25942

Received: 12/03/2019

Respondent: Environment Agency

DM1 - Sustainable Construction. The policy should further make clear that the use of infiltration SuDS, may not be suitable at some sites where contamination is present. Alternative SuDS features should be used in those circumstances.

Object

Representation ID: 25943

Received: 12/03/2019

Respondent: Environment Agency

Policy DM4 - Development and Flood Risk. The SFRA is again mentioned here and needs to be updated to remain useful. Paragraph 9.43 refers to the suitability of different types of developments within the various flood zone classifications. It should be noted that the Flood Zones will have changed and the outline of Flood Zone 3b may need to be updated. Plan 2 - Flood Risk, dated November 2018 maps the flood zone. This is different to our current flood maps. Our flood map for planning was updated on 31 January 2019

Object

Representation ID: 25944

Received: 12/03/2019

Respondent: Environment Agency

Paragraph 9.44 refers to the Ipswich Level 2 SFRA providing the necessary information to help facilitate the sequential approach as outlined in the NPPF demonstrating the application of the sequential test is essential. We are currently reviewing the Sequential and Exception Test statement and will advise of any further work required.

Object

Representation ID: 25945

Received: 12/03/2019

Respondent: Environment Agency

We are pleased to see that paragraph 9.4.9 requires the production of site specific FRAs to include detailed flood modelling to ascertain flood risk. However, the paragraph also refers to the SFRA. As previously stated, you may wish to update your SFRA because there is new ENS (Essex Norfolk and Suffolk) Coastal Modelling 2018, to which site specific Flood Risk Assessments would have to refer to in line with paragraph 160 of the NPPF.

Object

Representation ID: 25946

Received: 12/03/2019

Respondent: Environment Agency

Paragraph 9.4.10 states that "FRAs for proposals in Zones 2 and 3 need to clearly state the frequency of flooding in and around the site and, until the EA's flood defence barrier is implemented, will need to assume existing defences are in place". This sentence is now no longer fully applicable as the tidal barrier is now complete and operational and should be updated accordingly. The paragraph should also consider residual risk.

Object

Representation ID: 25947

Received: 12/03/2019

Respondent: Environment Agency

DM8 - The Natural Environment- should be refined to say that "Sites of Special Scientific Interest (SSSI) will be protected from development". Similarly, the policy wording for the planning permission section should be strengthened to state that "planning permission will not be granted for development that would result in damage or loss in extent or otherwise have significant adverse effect on Local Nature Reserves or Local Sites".

Object

Representation ID: 25948

Received: 12/03/2019

Respondent: Environment Agency

Policy DM8 - The Natural Environment - the sixth paragraph should be strengthened to say "Enhancements for protected sites and protected and priority species will be expected from new development". The wording of the final paragraph in the policy should be strengthened to say "Within the buffer zones around core areas and corridors, development will be required to enhance the ecological networks through measures such as wildlife beneficial landscaping".