Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Paragraph 6.16 states that the Strategic Flood Risk Assessment (SFRA) has been revised. However, this is currently being updated so this section should be amended. The Local Plan should also refer to the SFRA as being a living document.

Our full comments in relation to this can be found within our response to policy DM4 - Flood Risk. This is the main reason for our objection comment.

We are pleased that paragraph 8.41 refers to UKCP18.
Paragraph 8.44 refers to buildings at risk of flooding through tidal surges and heavy rain. However, this paragraph does not specifically refer to fluvial flood risk. We therefore would require this to be updated accordingly.
Paragraph 8.45 refers to the SFRA. The SFRA is a living document and should be updated when new modelling becomes available.

Our main comments that need to be actioned relating to the SFRA can be found within our response to policy DM4 - Flood Risk.

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This plan includes a statement which says “This plan of nationally designated flood zones relates to fluvial flooding. Further information on pluvial (surface water) flooding can be found in the Strategic Flood Risk Assessment (SFRA).” This statement is incorrect as the plan shows both fluvial and tidal flooding. This will also need to be updated when the new modelling which will be within the living SFRA when completed.

Our full comments on the SFRA can be found in our response to policy DM4 - Development and Flood Risk.

At present, we are raising an unsound representation on Flood Risk grounds. This is because the evidence base that informs the Local Plan is not yet finalised. The Strategic Flood Risk Assessment (SFRA) has not yet been agreed as the River Gipping fluvial model is not yet verified and ready for use. This is because we are still awaiting the final outputs and deliverables for this model. Therefore, there is not currently a reliable evidence base to derive the SFRA and inform the Local Plan. We have and will continue to work in partnership with Ipswich Borough Council on the SFRA. As soon the modelling is completed we will be able to engage further to ensure that the SFRA is finalised and the Local Plan appropriately reflects its findings. A statement of common ground will be prepared if required.
In addition to the above, we have included our comments below on the rest of the Local Plan document. These have been provided in the same format as the Local Plan itself.

In terms of the rest of the policy itself:
Paragraph 9.4.10 needs to make reference to the fact that the SFRA is a living document and is awaiting modelling information to update it.
We fully agree with paragraph 9.4.12 which states that more and less vulnerable development in Flood Zones 2 and 3a may be acceptable but will require Flood Risk Assessments (FRAs) to demonstrate that such developments will be safe.