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Representations on BMSDC Joint Local Plan Consultation Document (Interactive) - Climate Change
COMMENT Suffolk County Council (Mr. Robert Feakes)
It is recommended that the new Local Plan refer to the mitigation of surface water flooding, the protection of the water quality of watercourses and enhancement of the natural environment.
COMMENT Environment Agency (Miss Charlie Christensen)
Considering that a number of fluvial models used in these SFRAs have been superseded, you should review the SFRAs against our new models and decide whether the SFRAs need to be updated. You should ensure that the plan is prepared with the most up to date evidence base and use the most appropriate evidence base to prepare flood risk and climate change policies. You will also need to demonstrate that the flood risk sequential test has been applied to site allocations. If you intend to undertake a new SFRA, we would recommend discussion with ourselves with regards to this work.
COMMENT Historic England (Katie Parsons)
We invite a specific policy relating to the inclusion of renewable technologies within Conservation Areas and with regard to historic buildings and the wider historic landscape. A sustainable approach should ensure a balance between the benefits that such development delivers and the environmental costs it incurs. Policy should seek to limit and mitigate any such cost to the environment.
Listed buildings, buildings in conservation areas and scheduled monuments are
exempted from the need to comply with energy efficiency requirements of the
Building Regulations where compliance would unacceptably alter their character and
appearance. Special considerations under Part L are also given to locally listed
buildings, buildings of architectural and historic interest within registered parks and
gardens and the curtilages of scheduled monuments, and buildings of traditional
construction with permeable fabric that both absorbs and readily allows the
evaporation of moisture.
OBJECT Professor Robert Turner & Mrs J.M. Turner
On the Old Stowmarket Road site for which approval has already been granted, flooding occurs in the north east corner but the developers have been careful to set aside that area for private self build properties and have not allocated their own properties to this area. This is an area where there is a very large, deep and dangerous lake.
COMMENT Mr Ken Seager
Issues to consider:
* the range of technologies that could be accommodated and the policies needed to encourage their development in the right places;
* the costs of many renewable energy technologies are falling, potentially increasing their attractiveness and the number of proposals;
* different technologies have different impacts and impacts can vary by place;
* the UK has legal commitments to cut greenhouse gases and meet increased energy demand from renewable sources. Whilst local authorities should design their policies to maximise renewable and low carbon energy development, there is no quota which the Local Plan has to deliver.
COMMENT Ms Helen Davies
Being close to the coast and on the River Gipping, flooding is an issue for us. Development should not be done in flood zones. Any flood mitigation measures should also consider the impact of the measures both upstream and downstream in Sproughton.
COMMENT Mr Peter Powell
Policy that considers climate change is welcomed and although much more could probably be done full compliance or better of national standards for building and NPPF requirement must be the minimum.
We are fortunate that wind farms for Suffolk can be set well offshore in the relatively shallow North Sea and it should be possible to site solar farms where they have no impact on the landscape.
For Sproughton a big concern is flooding.
COMMENT MSDC Green Group (Cllr John Matthissen)
See submission for fuller comments
We suggest BMSDC define sustainable development as "Development that supports the transition to a zero carbon economy." The need for policies to address climate change, both mitigation and adaptation, should run like a green thread throughout Local Plan policies.
COMMENT Mrs Louise Baldry
Due to changing weather patterns the threat from flooding is becoming more uncertain along the river valley and SUDS are not adequate for sustained rainfall events especially in flood zones.A more robust critical assessment on SUDS on new developments feeding into river valleys and flood plains and should be designed and built not to reduce additional flood risk but to eliminate any risk
COMMENT Babergh Green Party (Mr Robert Lindsay)
The National Planning Policy Framework insists on a "presumption in favour of sustainable development" but leaves it to councils to define sustainable development.
We suggest BMSDC define sustainable development as "Development that supports the transition to a zero carbon economy"
COMMENT Mr Richard Howard
Due to changing weather patterns the threat from flooding is becoming more uncertain along the river valley and SUDS are not adequate for sustained rainfall events especially in flood zones.
OBJECT David Howorth
I dispute the statement on p69: 'Whilst the planning system has a role to play in delivering sustainability in buildings, construction methods and the energy performance of buildings are primarily addressed via Building Regulations'. Building Regulations merely provide the minimum legal obligation. They most certainly do not set out or even describe sustainable building methods.
COMMENT Mr. Nick Miller for Sudbury Green Belt Group
A useful guide published in March 2017 sets out legal obligations on air quality: https://www.local.gov.uk/air-quality-briefing-directors-public-health - does the Draft Local Plan match up to this? We raise several issues.