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20 - DM8 Heritage Assets and Conservation

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Support

Core Strategy and Policies DPD Review - Pre-Submission of Main Modifications

Representation ID: 24222

Received: 17/11/2015

Respondent: Historic England

Representation:

Re-labelling Part (a) as 'designated and un-designated assets' and adding a third and fourth paragraph is helpful in terms of covering other heritage asset types and the issue of demolition. It provides the minimum required text to address our concerns, although in the new fourth paragraph, parks and gardens are 'registered', not 'scheduled'.

We welcome the modification to Part (b) in terms of point (i) which clarifies that a building/structure can be demolished if it does not make a positive contribution to the significance of the conservation area.

Full text:

We note the various proposed main modifications to Policy DM8 responding to the objections of Historic England and Suffolk County Council. Re-labelling Part (a) as 'designated and un-designated assets' and adding a third and fourth paragraph is helpful in terms of covering other heritage asset types and the issue of demolition. It provides the minimum required text to address our concerns, although in the new fourth paragraph, parks and gardens are 'registered', not 'scheduled'. Additional text on registered parks and gardens in the supporting paragraphs would be helpful. In paragraph 9.71, the Practice Guide to PPS5 has been withdrawn and replaced with Historic England Good Practice Advice Notes (see: www.historicengland.org.uk/advice/planning/planning-system/).

We welcome the modification to Part (b) in terms of point (i) which clarifies that a building/structure can be demolished if it does not make a positive contribution to the significance of the conservation area.

Object

Core Strategy and Policies DPD Review - Pre-Submission of Main Modifications

Representation ID: 24223

Received: 17/11/2015

Respondent: Historic England

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

We have concerns regarding the proposed main modifications to the archaeology paragraphs in Part (c) in terms of the deleted reference to the Area of Archaeological Importance (AAI). Removing reference to the AAI means that there is no policy guidance as to what the AAI means in terms of development proposals. We consider this modification to be unsound as it not effective in terms of delivering the plan. It does not provide sufficient clarity regarding the status of the AAI.

Full text:

We have concerns regarding the proposed main modifications to the archaeology paragraphs in Part (c) in terms of the deleted reference to the Area of Archaeological Importance (AAI). Removing reference to the AAI means that there is no policy guidance as to what the AAI means in terms of development proposals. The AAI is identified on the Policies Map (Plan 4) and covers the central area of Ipswich where archaeology is likely to be the most important. We consider this modification to be unsound as it not effective in terms of delivering the plan. It does not provide sufficient clarity regarding the status of the AAI.

Other proposed main modifications to Part (c) seek to address our concerns with the Proposed Submission draft by removing reference to only monitoring works. The modifications also attempt to respond to the representations of Suffolk County Council, but do not reflect all of the county council's suggestions.

While it does not form part of the current public consultation, we note the additional modification to paragraph 9.73 which addresses the representation of Suffolk County Council but also introduces wording regarding archaeology and planning. We also note the additional modification to paragraph 9.74 which seeks to clarify the purpose of the AAI, but does not justify the deletion of references to the AAI in the policy itself.

Object

Core Strategy and Policies DPD Review - Pre-Submission of Main Modifications

Representation ID: 24235

Received: 23/11/2015

Respondent: Crest Strategic Projects

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation:

Modifications to this Policy are not proposed, however our previous representations (Barton Willmore, March 2015) highlighted concerns regarding Part b. "Conservation Areas" which states that the position, height, mass and materials of a proposed building shall pay regard to the character of adjoining buildings. This is not objected to however, the weight that should be attached to the character of buildings should be proportionate to their status and this should be reflected in the Policy wording to ensure that it is 'justified'. [Note - DM8 Part b Conservation Areas has been modified.]

Full text:

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Support

Core Strategy and Policies DPD Review - Pre-Submission of Main Modifications

Representation ID: 24245

Received: 23/11/2015

Respondent: New Anglia LEP for Norfolk and Suffolk

Representation:

The County Council welcomes the amendment pertaining to archaeology, which is in line with earlier representations and subsequent discussion. The revised policy wording represents a much clearer approach to archaeological assessment which is proportionate and consistent with the intent of the NPPF. The minor modifications to the Core Strategy explain the role of the Area of Archaeological Importance in signposting developers as to where there is greater potential for archaeological finds. Ipswich's long history of occupation means that there is strong potential for significant finds in certain locations. This policy ensures that proper and proportionate assessment will be carried out.

Full text:

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Object

Core Strategy and Policies DPD Review - Pre-Submission of Main Modifications

Representation ID: 24315

Received: 21/12/2015

Respondent: Mr Matt Clarke

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

Policy DM8 (Heritage Assets and Conservation) has been modified in order to specifically include both Designated and Undesignated Assets. A number of additions are made to widen the scope of the policy. As with Policy CS4 above, whilst the intentions of the Council to safeguard the historic environment are acknowledged and supported in principle, this should not place additional unnecessary restrictions upon development, particularly in relation to key sites, such as the redevelopment of the Mint Quarter (with reference to site IP048).

Full text:

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