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

Object

Representation ID: 26010

Received: 13/03/2019

Respondent: Suffolk County Council

Clarify that part b) means the countywide flood risk guidance as source of 'adopted standards'. Also clarify that 'wherever practicable' point refers to the application of SuDS standards, rather than the requirement to ensure adequate protection from flood risk.

Support intent of clause (d) and keen to support measures which encourage water efficiency, but unclear how this criteria is intended to operate alongside the requirement in DM1.

A discussion on the best policy mechanism for encouraging re-use of land drainage water recommended.

Amend paragraph 9.4.8 to explain linkage between Plan, SPD and countywide guidance rather than paragraph 8.41.

Object

Representation ID: 26011

Received: 13/03/2019

Respondent: Suffolk County Council

Supporting text on open space proportions (paragraph 9.6.2) suggests specific proportions of sites for green space and notes that this space can contribute to part of a site's SuDS provision. This is helpful but it should be noted that, on some sites, 10% or more of the site area may be required for SuDS provision alone.

County would appreciate a discussion regarding the relationship between open space and highway design. Need to consider how planting relates to highway design and maintenance requirements, and opportunities for future widening. May be a matter for forthcoming design guidance, rather than local plan directly.

Object

Representation ID: 26012

Received: 13/03/2019

Respondent: Suffolk County Council

SuDS Definition (page 178):

It would be helpful to extend this definition of SuDS to state that SuDS are used to attenuate and treat runoff.

Object

Representation ID: 26014

Received: 13/03/2019

Respondent: Suffolk County Council

Have been joint-working with IBC and other ISPA authorities to model impacts of local plan growth. The latest assessment has been published alongside the Regulation 19 consultation of the SCDC Local Plan. It shows significant pressures on the network in Ipswich and certain A14 junctions.

The County is seeking to work with ISPA Authorities to develop more detailed proposals for limiting impacts of development through promoting sustainable modes of travel and means of securing funding.

Plan will need to include mechanisms to ensure funding of highway and sustainable transport improvements and possibly require policy for specific modal splits in development.

Object

Representation ID: 26017

Received: 13/03/2019

Respondent: Suffolk County Council

The objectives set out in this Policy are broadly appropriate, but our authorities need to carry out further work on the deliverability of these measures in order to incorporate them into an Infrastructure Delivery Plan.

The supporting text requires further consideration. Delivery of additional east-west capacity, in order to consider the sort of measures referred to in the 2007 Buchanan report (referred to in 8.221), is not currently programmed. Paragraph 8.223 should be updated to reflect the cancellation of the Upper Orwell Crossings project. Accordingly, the Borough Council should consider the re-wording of Objective 6 of the Plan, accordingly.

Object

Representation ID: 26018

Received: 13/03/2019

Respondent: Suffolk County Council

The County recognises that it has a role to play in managing poor air quality in Ipswich. In order to more effectively consider the relationship between vehicular movements arising from development and air quality, it may be appropriate to align the thresholds for Air Quality Assessment with the thresholds for Transport Assessment; i.e. 80 dwellings; or provide the rationale for the figure.

Maximising opportunities for healthy and sustainable travel will be fundamental for managing air quality issues in Ipswich. The Council could helpfully refer to specialist housing, e.g. care homes, as being a sensitive receptor (as noted in the policy).

Object

Representation ID: 26019

Received: 13/03/2019

Respondent: Suffolk County Council

The commitment to meeting adopted parking standards is welcomed, but we have
experience locally of severance plots resulting in a loss of parking for existing dwellings. The policy could helpfully reflect this issue by stating (in part g) that development should meet parking standards and not lead to an unacceptable loss of parking serving existing dwellings.

Object

Representation ID: 26020

Received: 13/03/2019

Respondent: Suffolk County Council

Support intent of policy but further discussion required in respect of car parking needs.

Assumed that 'operational' parking within the central car parking core doesn't refer to staff car parking - Please clarify.

Reference to secure cycle parking is welcomed, but 'security' needs to be defined and explained fully in supplementary guidance (E.g. Suffolk Guidance for Parking, forthcoming countywide design guidance or the IBC SPD). The supporting text could also explain that secure means a lockable facility away from public access, lit, covered and has natural surveillance. In respect of employment, cycle parking needs to be suitable for long stays

Object

Representation ID: 26021

Received: 13/03/2019

Respondent: Suffolk County Council

This policy includes a reference to traffic generation, with the implication being that the proposals would be refused if there is a 'significant individual or cumulative effect on traffic generation'. National policy states that proposals should only be refused on highway grounds if there is a severe impact. This policy should be redrafted to ensure consistency with the NPPF in respect of highway impacts or, if the intent is to manage the amenity impacts arising from night time vehicular movements, clarify that point.