ipswich.gov.uk

Object

Core Strategy and Policies DPD Review - Pre-Submission of Main Modifications

Representation ID: 24223

Received: 17/11/2015

Respondent: Historic England

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

We have concerns regarding the proposed main modifications to the archaeology paragraphs in Part (c) in terms of the deleted reference to the Area of Archaeological Importance (AAI). Removing reference to the AAI means that there is no policy guidance as to what the AAI means in terms of development proposals. We consider this modification to be unsound as it not effective in terms of delivering the plan. It does not provide sufficient clarity regarding the status of the AAI.

Full text:

We have concerns regarding the proposed main modifications to the archaeology paragraphs in Part (c) in terms of the deleted reference to the Area of Archaeological Importance (AAI). Removing reference to the AAI means that there is no policy guidance as to what the AAI means in terms of development proposals. The AAI is identified on the Policies Map (Plan 4) and covers the central area of Ipswich where archaeology is likely to be the most important. We consider this modification to be unsound as it not effective in terms of delivering the plan. It does not provide sufficient clarity regarding the status of the AAI.

Other proposed main modifications to Part (c) seek to address our concerns with the Proposed Submission draft by removing reference to only monitoring works. The modifications also attempt to respond to the representations of Suffolk County Council, but do not reflect all of the county council's suggestions.

While it does not form part of the current public consultation, we note the additional modification to paragraph 9.73 which addresses the representation of Suffolk County Council but also introduces wording regarding archaeology and planning. We also note the additional modification to paragraph 9.74 which seeks to clarify the purpose of the AAI, but does not justify the deletion of references to the AAI in the policy itself.