Missing from the whole of part B - the relationship of these sites to the Ecological Network does not seem to have been considered.

We have made separate representations on individual sites, but as a general comment, we have concerns regarding a number of sites and their potential impact on the historic environment. While we do not object to the principle of any site allocation, there is sometimes a lack of detail and/or clarity in terms of development constraints and issues in the site sheets contained in Appendix 3. In particular, scheduled monument and archaeological issues are not always properly addressed (see individual sites) in terms of what is required and the implications for potential development schemes. The archaeology of central Ipswich is still in the process of being mapped or understood, but it is a valuable and complex resource given Ipswich's importance as a settlement from the early medieval period onwards. Archaeology could act as a considerable constraint on the deliverability of sites and therefore needs clarity in terms of site-specific requirements (see separate representations). Proposals should acknowledge the archaeological potential of the site and adopt designs which preserve and enhance the historic environment. This could include creative use of open space within development proposals to assist with the preservation of archaeology. Early consultation and assessment is essential to ensue proposals take all aspects of the historic environment into consideration.

Our understanding of Ipswich's archaeology is evolving, which means that additional clarification may be required as the plan progresses towards adoption. Paragraph 157 of the NPPF requires Local Plans to provide adequate detail with site allocations (fifth bullet), with the Planning Practice Guidance providing further emphasis (PPG Reference ID: 12-010-20140306 (last revised 06/03/2014).

The status of the site sheets in Appendix 3 is not entirely clear. They are described as being "for information only", but they contain lots of detail that is relevant to specific proposals (even if in some cases, the detail is lacking or misleading). Appendix 3 is referred to in supporting paragraphs to each allocation policy (e.g. paragraph 4.8) and again in paragraph 5.7, but there appears to be no obligation to observe the development constraints and issues within the site sheets. We consider that the individual allocation policies should refer to the need to observe the site sheets in Appendix 3. Without these references, the plan is unsound as it is not effective in terms of deliverability against various constraints including heritage, or consistent with national policy.