This is a very sensitive site partly within the Central Conservation Area and containing Grade II listed buildings while adjoining other listed buildings, including the Grade II* 54-58 Fore Street to the north-east, the Grade II* Old Custom House to the south-west and the complex of highly graded listed buildings to the south-east at Isaac Lord. The archaeological issues include the Jewish Burial Ground, which appears to be excluded from the site allocation but could still be affected, plus archaeological potential across other parts of the site. The exclusion of the burial ground raises questions about how any redevelopment would respect this heritage asset in terms of its significance and setting. 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 many of the above heritage assets, the wording is not effective with regards to archaeological consideration. 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 in terms of archaeology. There could be nationally important archaeology within the site where development may not be appropriate. The revised site sheet should also be strengthened with regards to its wording on the conservation area and listed buildings, and better linked to national policy wording. Clarity is also needed regarding the burial ground.

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).

See attached.