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

Object

Representation ID: 26314

Received: 02/03/2020

Respondent: Suffolk Wildlife Trust

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Biodiversity Section currently states – “The need to halt biodiversity net loss.” Suggest this is amended to state - ”Prevent loss of biodiversity and implement measures for biodiversity net gain.” The government is mandating that, through the new Environment Bill, all development (with a few exceptions) will be required to secure gains in biodiversity. It is therefore not sufficient to state that there will be a halt in net loss.

Object

Representation ID: 26316

Received: 02/03/2020

Respondent: Suffolk Wildlife Trust

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

“9. NATURAL ENVIRONMENT – To protect and enhance high quality, accessible strategic and local open spaces rich in biodiversity and geodiversity for people to visit and use.“ Consider addition of reference to ecological networks and connectivity. NPPF references the need to establish, conserve, restore and enhance ecological networks under Paragraphs 173-d. and 174-b.

Object

Representation ID: 26317

Received: 02/03/2020

Respondent: Suffolk Wildlife Trust

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Conditions a. and c. in relation to SSSI's clearly conflict with Paragraph 175b of the NPPF which only allows for Condition b. (benefits outweighing impacts). This Policy should be updated to reflect this.

Object

Representation ID: 26318

Received: 02/03/2020

Respondent: Suffolk Wildlife Trust

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

In Policy DM12, point d. there should be an inclusion of the potential for installation of green roofs and walls as part of the strategy to introduce greener streets and spaces. This would make a more robust argument for the requirement for net gains in biodiversity.

Object

Representation ID: 26320

Received: 02/03/2020

Respondent: Suffolk Wildlife Trust

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We have been informed by the RSPB that a suggestion was made to add a further point to DM15 – Tall Buildings with regards to the provision of swift bricks in new buildings. This is a sentiment we share at the Suffolk Wildlife Trust, and we note that there are no references to Green Space or biodiversity measures within this policy, which appears to be a valuable missed opportunity. We propose the addition of a further point: k. to incorporate integrated swift bricks”. In addition to this, other biodiversity features could be noted here, such as
the provision of green walls and roofs which would help meet the biodiversity net gain requirements.

Object

Representation ID: 26321

Received: 02/03/2020

Respondent: Suffolk Wildlife Trust

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

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

Object

Representation ID: 26326

Received: 02/03/2020

Respondent: Suffolk Wildlife Trust

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Two of the sites (IP143 and IP067b) make up a substantial part of Green Corridor F, forming the semi-natural habitat link between the south-western boundary of Landseer Park Carr County Wildlife Site (CWS) and the western boundary of the Volvo Raeburn Road CWS. If these sites are fully developed, this ecological network would be interrupted. This is the longest existing ecological network in Ipswich, and if sensitive development is undertaken in the Ravenswood area, then this corridor could be continued to the east. See suggested extension route.

Object

Representation ID: 26327

Received: 02/03/2020

Respondent: Suffolk Wildlife Trust

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Two of the sites (IP143 and IP067b) make up a substantial part of Green Corridor F, forming the semi-natural habitat link between the south-western boundary of Landseer Park Carr County Wildlife Site (CWS) and the western boundary of the Volvo Raeburn Road CWS. If these sites are fully developed, this ecological network would be interrupted. This is the longest existing ecological network in Ipswich, and if sensitive development is undertaken in the Ravenswood area, then this corridor could be continued to the east. See suggested extension route. Map refers to Wildlife Audit 2012/2013, which is out-of-date (see 2019 update).

Object

Representation ID: 26328

Received: 02/03/2020

Respondent: Suffolk Wildlife Trust

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Two of the sites (IP143 and IP067b) make up a substantial part of Green Corridor F, forming the semi-natural habitat link between the south-western boundary of Landseer Park Carr County Wildlife Site (CWS) and the western boundary of the Volvo Raeburn Road CWS. If these sites are fully developed, this ecological network would be interrupted. This is the longest existing ecological network in Ipswich, and if sensitive development is undertaken in the Ravenswood area, then this corridor could be continued to the east. See suggested extension route.

Object

Representation ID: 26575

Received: 02/03/2020

Respondent: Suffolk Wildlife Trust

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

In addition to the points made under Policy DM17 regarding small scale residential developments for infill, backland or severance plots, a point should also be made to deny permission for any development which could result in an unacceptable loss of semi-natural habitat, which could be important in its own right, or support protected and/or priority species.