6.1
Object
Proposed Submission Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document
Representation ID: 5257
Received: 05/03/2015
Respondent: Historic England
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
We welcome the identification of opportunity areas. However, the identification of development options in each opportunity area does not always correspond with site allocations and often goes much beyond the boundaries of proposed allocations. This potentially creates some confusion and needs clarifying. While we welcome the identification of development principles for each opportunity area, this does not overcome the need for the individual site sheets to contain specific development criteria. The key for each diagram shows listed buildings but not scheduled monuments, which is not helpful in terms of clarity.
We welcome the identification of opportunity areas to focus development and regeneration in a coordinated way and the strong link to policy through their reference in Policy CS3. However, the identification of development options in each opportunity area does not always correspond with site allocations and often goes much beyond the boundaries of proposed allocations (e.g. Area B and C). This potentially creates some confusion and needs clarifying. While we welcome the identification of development principles for each opportunity area, this does not overcome the need for the individual site sheets to contain specific development criteria (see separate representations). The key for each diagram shows listed buildings but not scheduled monuments, which is not helpful in terms of clarity.
As currently drafted in relation to opportunity area diagrams, we consider that the plan is unsound as it is not effective or consistent with national policy. The NPPF requires adequate detail to be provided in Local Plans (e.g. paragraphs 154 and 157), while Local Plans should set out a positive strategy for the historic environment (paragraph 126).