Policy SP2: Land Allocated for Housing
We note the proposed main modification to add five additional site allocations to Policy SP2, for sites where planning permission has lapsed or applications have been withdrawn. We have comments to make on two of these sites as follows:

* IP011a: Lower Orwell Street
We note this site had planning permission for student accommodation which lapsed in October 2014. While we do not object to the principle of this site being developed, we have concerns with the information provided on the site sheet that follows the main modifications table. Around two-thirds of the site is designated as a scheduled monument, and therefore is not 'adjacent to a scheduled monument' as stated in the site sheet. Furthermore, the wording relating to archaeology and scheduled monuments needs to be consistent with the wording used for other similar allocations. Our representations on sites such as IP011b, IP035, IP043, IP048 and IP054 sought amendments to their site sheets to ensure effectiveness and consistency with national policy. We note that there are additional modifications which propose amendments to a number of the site sheets, but these are not part of this public consultation. We would welcome the opportunity to comment on these separately, given that our representations raised issues relating to soundness.

The site sheet for IP011a 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. Furthermore, while the site sheet refers to the adjoining conservation area and listed building, there is no explanation of the implications for development in terms of these heritage assets.

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 NPPF requires Local Plans to provide adequate detail with site allocations (fifth bullet), with the Planning Practice Guidance providing further emphasis (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).



[Comments on IP132 - see separate representation]

* IP132: Former St Peter's Warehouse site, 4 Bridge Street
We note this site had planning permission for a mixed use scheme which lapsed in April 2014. This permission included 48 dwellings, while the new allocation and proposed main modification seeks 73 dwellings to reflect the successful bid for the site. While we do not object to the principle of this site being developed, we have concerns with the lack of information provided on the site sheet that follows the main modifications table.

We have provided pre-application advice on this site in our letter dated 19 December 2014 as part of the recent acquisition. The site lies within the Central Conservation Area and adjoins the Wet Dock Conservation Areas, and includes 4 College Street, listed grade II. On the opposite side of the road are the Church of St. Peter, grade II* and Wolsey's Gate, a scheduled monument. The land on the opposite side of the roundabout is also scheduled.

Our advice acknowledged that the waterfront has seen considerable change over recent years with many sites being redeveloped to include a number of tall buildings while amongst these a number of smaller scale historic buildings survive. To the north there is an aspiration to improve the connections between the waterfront and the town centre and to try to mitigate the challenges presented by the roads here. There is also scope to enhance the setting of the two grade II* churches, St. Peter and St. Mary on the Quay.

Our advice stated that any future proposal for the redevelopment of the site should be informed by a thorough analysis of the surrounding townscape and historic environment and, in line with national planning policy, should aim to sustain and enhance the significance of the heritage assets here. We are supportive of the desire to strengthen connectivity between the waterfront and town centre.

While the site sheet for IP132 refers to the Central Conservation Area and the listed building at 4 College Street, it does not mention the Wet Dock Conservation Area, the listed church or the listed and scheduled Wolsey's Gate. There is also no recognition of non-designated buildings within the site that have heritage interest. Furthermore, there is no explanation of the implications for development in terms of these heritage assets.

As currently drafted, we consider the plan to be unsound in terms of its effectiveness and consistency with national policy. Paragraph 157 of the NPPF requires Local Plans to provide adequate detail with site allocations (fifth bullet), with the Planning Practice Guidance providing further emphasis (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).

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See attached.