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

Support

Representation ID: 25613

Received: 08/03/2019

Respondent: Suffolk Wildlife Trust

We support the references in the Objectives 5 and 8 to protecting, enhancing and extending the Borough's strategic greenspace and ecological networks.

Object

Representation ID: 25614

Received: 08/03/2019

Respondent: Suffolk Wildlife Trust

We consider that policy ISPA2 should also include delivery of strategic green infrastructure alongside the other types of infrastructure listed.

Support

Representation ID: 25615

Received: 08/03/2019

Respondent: Suffolk Wildlife Trust

We support the cross-boundary approach proposed in this policy for assessing and mitigating impacts on European designated sites.

Object

Representation ID: 25616

Received: 08/03/2019

Respondent: Suffolk Wildlife Trust

Whilst we note that this policy includes reference to a 'green rim' for walking and cycling, it should be expanded to make reference to cross-boundary working to deliver strategic green infrastructure. Such green infrastructure should deliver benefits for both people and biodiversity and help new developments deliver biodiversity net gain.

Object

Representation ID: 25617

Received: 08/03/2019

Respondent: Suffolk Wildlife Trust

We support the intention of this policy to protect the Borough's biodiversity, trees and soils. We recommend that paragraph 8.65 should include reference to the Conservation of Habitats and Species Regulations (2017).

Also policy CS4 states that there are 20 County Wildlife Sites in the Borough, however paragraph 9.8.3 states that there are 19. This should be checked for consistency.

Support

Representation ID: 25618

Received: 08/03/2019

Respondent: Suffolk Wildlife Trust

We support the intentions of this policy to enhance and extend the ecological networks and green corridors in the Borough, including through requiring new open space to include enhancements for biodiversity.

Support

Representation ID: 25619

Received: 08/03/2019

Respondent: Suffolk Wildlife Trust

We support the inclusion of strategic green infrastructure and the Recreational Disturbance Mitigation Strategy in this policy.

Object

Representation ID: 25620

Received: 08/03/2019

Respondent: Suffolk Wildlife Trust

We are concerned that this policy fails to consider the potential ecological impact of the loss of open spaces, sports and recreation areas. Any such proposal should include assessment of such impacts and should follow the mitigation hierarchy to avoid, mitigate or compensate the impact.

Object

Representation ID: 25621

Received: 08/03/2019

Respondent: Suffolk Wildlife Trust

Whilst paragraph 9.6.7 recognises that green spaces should provide wildlife habitats as part of the wider ecological network, this does not appear to be included as part of policy DM6. The policy should include the requirement for new open spaces, sport and recreation facilities to provide ecological enhancements as part of their design and implementation, in order to create multi-functional spaces which are of value to people and wildlife.

Object

Representation ID: 25622

Received: 08/03/2019

Respondent: Suffolk Wildlife Trust

We support the intentions of this policy. However, the text in relation to SSSIs does not appear to be compliant with NPPF paragraph 175(b).

The Priority Habitats and Species sections must also include reference to development delivering ecological enhancements as part of their design and implementation. Enhancements for species such as swifts and hedgehogs should be secured as part of new residential developments.

The intention in the final sentence to encourage development to enhance the ecological network where possible is not supranational enough. All new development should deliver ecological enhancements as per the NPPF (paragraph 170(d)).