We believe the Local Plan is of sound judgement and agree with what has been proposed.

This is a very sensitive site partly within the Central Conservation Area and containing two Grade II listed buildings and two scheduled monuments with considerable archaeological potential across the site. The site is flanked by the conservation area and several listed buildings on its western and eastern side, with two Grade II* churches to the south (St Peter's and St Mary at the Quay) plus the site of the medieval priory. 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 some of the above heritage assets (and helpfully refers to retaining the part of the Lower Brook Street frontage within the conservation area), it does not refer to the listed buildings and 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 buildings, 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).