DM8 refers to proposals to listed buildings which may affect the fabric or setting of the building. The setting of listed buildings can also be impacted by proposals to nearby unlisted buildings - also covered by the statutory duty set out in para 9.66 - a policy which aims to 'protect our assets' should reflect this.

We welcome the additions to this policy from the previous 2014 consultation to widen its focus from just conservation areas. However, there are still some categories of heritage asset missing, namely historic parks & gardens (both nationally designated ones and local non-designated ones) and scheduled monuments. There is no reference to the former other than paragraph 8.55, which is very limited and should be remedied. The latter is partly addressed by the archaeology paragraphs in the policy, but there is nothing explicit about scheduled monuments in the policy. Paragraphs 8.53 and 9.73 refer to EH having national policies for scheduled monuments to protect them, but in reality other than the NPPF and general guidance/advice, there is no 'national' policy hence the need for something explicit at the local level.

In terms of what is in the current draft policy, the listed building paragraphs are reasonable, although there is nothing on demolition (paragraph 9.68 mentions demolition, but this is not covered in the policy). In addition, the first paragraph should simply refer to "significance" rather than "historical significance". The conservation area paragraphs are reasonable, although do not refer to significance as the catch-all NPPF term. In addition, point (i) should clarify that only buildings that do not make a positive contribution to the significance of the conservation area will be considered for demolition (in line with NPPF Paragraph 138).

The archaeology paragraphs are generally reasonable (notwithstanding the scheduled monument omission) and we welcome the identification of an Area of Archaeological Interest covering the core of Ipswich with the greatest potential for archaeological remains. However, the third paragraph needs re-phrasing because it makes provision for monitoring only, rather than evaluation and upfront excavation. The wording of the fourth paragraph is better, referring to an appropriate programme of archaeological investigation in the second sentence (but this only relates to locations outside of the Area of Archaeological Importance). The third paragraph should be amended in a similar fashion to the effect that an appropriate programme of archaeological work could consist of evaluation, upfront excavation and/or monitoring by an archaeological contractor.

The final paragraph of the draft policy relates to climate change. While the wording is reasonable, it is not clear from first glance that this is a separate part of the policy (it appears to be part of the archaeology paragraphs). It should be given a separate heading for clarity.

Based on the above issues, we consider the policy is unsound as it is not effective in terms of deliverability against heritage constraints or consistent with national policy which takes a more holistic approach to the historic environment (including paragraphs 126, 156 and 157).

See attached

See attached.