This is a very sensitive site where much care will need to be taken to avoid harming the historic environment. In particular, the site contains three scheduled monuments, with considerable archaeological potential across the site. The site also adjoins the Central Conservation Area to the north and west, with the Wet Dock Conservation Area to the south, along with the Grade II* Church of St Mary at the Quay, which are all development issues. The above heritage assets greatly influence the redevelopment of the site. We note that the Sustainability Appraisal identifies potential negative effects from this site on the historic environment (Objective ET9).

Although the revised site sheet now refers to the above heritage assets, the wording is not effective with regards to archaeological considerations. The extent of archaeological potential within this site and the wider area is not fully understood and the site sheet incorrectly suggests that there would be no objection in principle to development outside of the scheduled areas. There could be nationally important archaeology beyond the scheduled areas where development may be constrained. The revised site sheet should also be strengthened with regards to its wording on the conservation areas and listed church, and better linked to national policy wording.

As currently drafted, we consider the plan to be unsound in terms of its effectiveness, deliverability and consistency with national policy. Paragraph 157 of the National Planning Policy Framework requires Local Plans to provide detail with site allocations where appropriate (fifth bullet point), with the Planning Practice Guidance stating "where sites are proposed for allocation, sufficient detail should be given to provide clarity to developers, local communities and other interests about the nature and scale of development (addressing the 'what, where, when and how' questions)" (PPG Reference ID: 12-010-20140306 (last revised 06/03/2014). Conservation of the historic environment is a core planning principle (Paragraph 17) and Local Plans should set out a positive strategy in this respect (Paragraph 126).