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

Object

Representation ID: 25949

Received: 12/03/2019

Respondent: Environment Agency

DM8 - The Natural Environment. 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".

Object

Representation ID: 25950

Received: 12/03/2019

Respondent: Environment Agency

The policy should include reference to Biodiversity Net Gain. The Defra 25 Year Plan (2018), available here https://www.gov.uk/government/publications/25-year-environment-plan, includes a policy to embed the 'environmental net gain' principle
for development. This will enable development without increasing overall burdens on developers. The planning system should provide biodiversity net gains where possible as required in NPPF paragraph 170.

Object

Representation ID: 25951

Received: 12/03/2019

Respondent: Environment Agency

Paragraph 9.8.7 could be enhanced by making reference to the river corridor, preferably in a standalone paragraph, describing how new development along the river corridor will be required to enhance the biodiversity value of the riparian zone and ensure water quality is protected and enhanced.

Object

Representation ID: 25952

Received: 12/03/2019

Respondent: Environment Agency

We welcome the inclusion of Policy DM9 - Protection of trees and hedgerows. As stated in our response to paragraph 8.43, trees are important in helping to keep rivers cool. They provide shade and moderate the extremes in water temperature which can be detrimental to fish spawning. 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. The plan should make reference to the value of retaining existing and planting new riparian trees of appropriate native species of local provenance where this is possible.

Object

Representation ID: 25953

Received: 12/03/2019

Respondent: Environment Agency

It is good to see the inclusion of Policy DM10 - Green Corridors. The policy could be further enhanced by stating that development within close proximity to river banks should consider tree planting where appropriate and ensure that an appropriately sized ecological buffer along the river is maintained.

Object

Representation ID: 25954

Received: 12/03/2019

Respondent: Environment Agency

We welcome the reference to mitigation measures being required in regards to contamination in policy DM18 - Amenity. Paragraph 9.18.11 specifically refers to contaminated land and states that development on contaminated land can expose people to a wide range of potential health risks. This sentence should be enhanced by stating that is can also mobilise contaminants and cause pollution of controlled waters.

Object

Representation ID: 25955

Received: 12/03/2019

Respondent: Environment Agency

We are pleased to see paragraph 9.18.11 states that "applicants who wish to develop suspected contaminated land will be required to undertake a thorough investigation of the site to determine any risk". This could be further enhanced by adding that it will be required to undertake a thorough investigation to determine any risk to human health and controlled waters (including groundwater).

Object

Representation ID: 25956

Received: 12/03/2019

Respondent: Environment Agency

DM21 - Car and Cycle Parking in New Development includes reference to flood risk in paragraph 9.21.6 by stating that this is acceptable in flood risk terms as demonstrated through a Flood Risk Assessment. When considering car parking within flood risk areas, the ability of people to move their cars within the flood warning time should be considered. Long-term and residential car parking is unlikely to be acceptable on areas which regularly flood to a significant depth due to the risk of car owners being away from the area and being unable to move their cars when a flood occurs.

Object

Representation ID: 25957

Received: 12/03/2019

Respondent: Environment Agency

Policy DM21 - Car and Cycle Parking in New Development -Car parking can be appropriate in areas subject to flooding, provided that flood warnings are available and signs are in place however, ideally car parks should not be subject to flood depth in excess of 300mm since vehicles can be moved by water of this depth. Boundary treatments such as railings should ensure that if vehicles become mobilised during a flood event, they are contained within the confines of the site but still allow the free movement of flood water.

Object

Representation ID: 25958

Received: 12/03/2019

Respondent: Environment Agency

Chapter 10 - Implementation
Table 8A refers to the Ipswich Flood Defence Management Strategy. The Ipswich tidal barrier is now complete and this row of the table should be updated accordingly.