This is a very sensitive site, where approximately half of the site is designated as a scheduled monument (part of the Saxon town) and there is considerable archaeological potential across the whole site. The site also adjoins the Central Conservation Area to the south and listed buildings to the south and east, with a locally listed façade along Carr Street. 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 (and helpfully refers to the need to retain the locally listed façade on Carr Street), the wording is not effective with regards to archaeological considerations, particularly with regards to the scheduled monument. The extent of archaeological potential within this site and the wider area is not fully understood and there could be nationally important archaeology within the site 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).

See attached

Site IP048 - the area of this site that sits closest to Upper Brook Street should be allocated for a modern 'big-box' retail cluster. We envisage something like an out-of-town retail development with parking, built on this in-town site.