Object

Representation ID: 708

Received: 10/03/2014

Respondent: Natural England

Disagree with the conclusion of the AA for DM44 site IP149 that, if amended to add mitigating principles, the policy would not have an adverse effect on the integrity of the SPA/Ramsar site. The AA provides insufficient information regarding;
- Existing interest in the area of the SPA which could be disturbed e.g. bird numbers
- Existing levels of disturbance
- Likely additional disturbance resulting from visitor centre
- Residual impact with mitigation in place
- Monitoring and management proposals to ensure impacts remain insignificant.
There is also no consideration of potential alternative locations in less sensitive areas.

Object

Representation ID: 709

Received: 10/03/2014

Respondent: Natural England

We are satisfied with the conclusion of the AA that, provided Site IP262 is amended to include the recommended mitigation principles, it is likely that disturbance increases would be minimised and there would be no adverse effect on the integrity of the SPA/Ramsar site. The mitigation recommendations include design features, requirements for no new quay facilities/dredging, and a construction period that is sensitive to the need to avoid disturbance to the estuary. If the site allocation is not amended thus, developers should be made aware of the great sensitivity of developments and the requirement for project level Appropriate Assessment.

Object

Representation ID: 710

Received: 10/03/2014

Respondent: Natural England

The AA concludes that the plan's policies don't have cumulative effects on European sites and the whole plan has no greater likely significant effect than that resulting from Policy DM44 and DM46 alone, over and above cumulative effects assessed for the Core Strategy Review. If the latter is found to have no adverse effect on any European site outside Ipswich, the Site Allocations DPD would similarly have no impact. The Core Strategy AA will need amendment in line with our comments, to reach a satisfactory conclusion of no adverse effect and thus enable this 'in combination' effect to be resolved.

Object

Representation ID: 711

Received: 10/03/2014

Respondent: Natural England

We are reasonably satisfied that the Interim SA considers the impacts of the Site Allocations DPD on relevant aspects of the environment within our remit. We particularly welcome SA objectives to protect/enhance designated sites and non-designated areas of biodiversity. However, there are areas where the assessment does not fully address potential biodiversity impacts and mitigation requirements. The SA identifies some allocations with potential to adversely affect biodiversity. 4.4.2 includes mitigation recommendations which should be included in the DPD. Section 4.4.2 should also include a recommendation requiring that all proposals be subject to at least a desk top ecological assessment.

Object

Representation ID: 712

Received: 10/03/2014

Respondent: Natural England

With regard to the IP149 Pond Hall Carr and Farm allocation the SA only identifies positive outcomes for biodiversity. Whilst recognising the proximity of the site to the Stour and Orwell Estuaries SPA and Ramsar the SA fails to acknowledge the potential for the allocation to have an adverse effect on this European site through increased recreational disturbance, as identified through the AA. Natural England advises that the AA be amended in accordance with our comments above and the revised conclusions and recommendations of the AA should then be included in the SA and Policy DM44 of the DPD.

Support

Representation ID: 5110

Received: 10/03/2014

Respondent: Natural England

Natural England is satisfied with the conclusion of the AA that it could be ascertained there would be no adverse effect on the integrity of any European site resulting from these policies.