Proposed Submission Core Strategy and Policies Development Plan Document Review

As stated in our response to the 2013 consultation, the vision makes little reference to the historic environment. Given that the NPPF requires local plans to set out a positive strategy for the conservation and enhancement of the historic environment (paragraph 126), the vision should contain explicit reference to how the Local Plan will address Ipswich's historic environment and heritage assets. Without such reference, we consider the Core Strategy is unsound as it is not consistent with national policy.

We welcome the amendments to the objectives following our response to the 2013 consultation, and the more holistic reference to the historic environment in Objective 8.

We generally support the principle of concentrating development in the town centre and adjoining areas, but only where it does not compromise heritage assets and the distinctive character of Ipswich. We still have some concerns regarding the use of high densities within the town centre, Ipswich Village and Waterfront, but welcome the additional wording regarding heritage assets and the historic character of Ipswich at the end of the policy.

The supporting text offers some helpful recognition of the design and conservation issues relating to the location of development, including acknowledgement of the NPPF's requirements in paragraph 8.39. We welcome the reference to the urban character study, which has been prepared as a SPD.

The IP-One Area contains the greatest concentration of heritage assets within the town (both designated and non-designated) and is a location that requires both conservation and change. We welcome the amendments to part (e) of Policy CS3 that requires the AAP to have policies that identify heritage assets which development proposals will need to have regard to. We note part (c) which provides a strong policy link to the Opportunity Areas contained within the AAP. It will be important that these opportunity areas contain adequate development principles relating to the historic environment (see separate representations).

Our response to the 2013 consultation expressed the need for a more explicit and holistic approach to the historic environment in the Core Strategy (and Site Allocations DPD) in order to address the requirements of the NPPF (particularly paragraphs 126, 156 and 157). The previous version of Policy CS4 made a general reference to" historical assets" in the first sentence and referred to conservation areas in the second sentence, but the supporting paragraphs stated that the Council would rely on national legislation and policy for listed buildings (8.46) and scheduled monuments (8.53)

We note the amendments to Policy CS4 and the supporting paragraphs in relating to the historic environment, but our concerns remains. The new third sentence in Policy CS4 is limited and effectively delegates the conservation and enhancement of heritage assets to the development management policies. This does not meet the NPPF requirement for a positive strategy to the historic environment (paragraph 126) or constitute a strategic policy approach (paragraph 156). The development management policies are important, but there is a need for a more explicit strategic policy approach. There is a strategic approach to biodiversity in the policy, and we consider that a similar approach should exist for the historic environment.

Paragraphs 8.46 and 8.53 still state that the Council will rely on national legislation, policy and guidance for listed buildings and scheduled monuments, while paragraph 8.55 underplays the status of registered parks and gardens as just a material consideration in planning applications (when they are designated heritage assets in the NPPF, potentially of the highest significance).

As currently drafted, Policy CS4 and the supporting paragraphs (8.46, 8.53 and 8.55) are unsound as they are not consistent with national policy in respect of the NPPF.

In order to achieve soundness, the third sentence of Policy CS4 should avoid merely delegating to the development management policies and should set out a strategic approach similar to what is set out for biodiversity. It could read as follows:

"The Council will conserve and enhance heritage assets within the Borough in a manner appropriate to their significance. This will include the use of planning obligations to secure the enhancement of the significance of any heritage asset, the maintenance of a list of buildings and other heritage assets of local importance, and steps to reduce the number of heritage assets "at risk" and improve historic shopfronts and public realm.

Paragraph 8.46 should be amended to set out the Council's local and strategic approach to listed buildings (not just relying on national legislation and policy). The second sentence of Paragraph 8.53 should be deleted. The second sentence of Paragraph 8.55 should read "Whilst registration offers no additional statutory protection, they are designated heritage assets of considerable significance and an important material consideration in development management"

As a minor change to ensure accuracy with the NPPF, the first sentence of Policy CS4 should be amended to read "heritage" rather than "historical", as heritage assets is a nationally defined policy term.

We welcome improved reference to the historic environment in Part C of the policy, although to ensure accuracy with the NPPF, "historic assets" should be amended to "heritage assets" as a nationally defined policy term.

We welcome the reference to heritage and archaeology as part of cultural and community facilities as a broad category of infrastructure to be secured or financed from new development.

We welcome Part (e) of the policy relating to the special character and distinctiveness of Ipswich. The completion of the Urban Characterisation Study SPD would help to support this policy.

While we generally welcome the criteria within this policy regarding tall building proposals, it is not clear whether this policy has been reviewed since the adoption of the original Core Strategy to see whether it remains justified and effective. We maintain that a comprehensive and thoroughly modelled policy is required, as well as a general policy approach on the identification of strategic views. Part (j) of the policy helpfully refers to conservation areas, but should be strengthened by reference to listed buildings and other heritage assets. As currently drafted, the plan is unsound as the policy is not effective in terms of deliverability against heritage constraints or consistent with national policy which takes a more holistic approach to the historic environment (including paragraph 126, 156 and 157).

We welcome the additions to this policy from the previous 2014 consultation to widen its focus from just conservation areas. However, there are still some categories of heritage asset missing, namely historic parks & gardens (both nationally designated ones and local non-designated ones) and scheduled monuments. There is no reference to the former other than paragraph 8.55, which is very limited and should be remedied. The latter is partly addressed by the archaeology paragraphs in the policy, but there is nothing explicit about scheduled monuments in the policy. Paragraphs 8.53 and 9.73 refer to EH having national policies for scheduled monuments to protect them, but in reality other than the NPPF and general guidance/advice, there is no 'national' policy hence the need for something explicit at the local level.

In terms of what is in the current draft policy, the listed building paragraphs are reasonable, although there is nothing on demolition (paragraph 9.68 mentions demolition, but this is not covered in the policy). In addition, the first paragraph should simply refer to "significance" rather than "historical significance". The conservation area paragraphs are reasonable, although do not refer to significance as the catch-all NPPF term. In addition, point (i) should clarify that only buildings that do not make a positive contribution to the significance of the conservation area will be considered for demolition (in line with NPPF Paragraph 138).

The archaeology paragraphs are generally reasonable (notwithstanding the scheduled monument omission) and we welcome the identification of an Area of Archaeological Interest covering the core of Ipswich with the greatest potential for archaeological remains. However, the third paragraph needs re-phrasing because it makes provision for monitoring only, rather than evaluation and upfront excavation. The wording of the fourth paragraph is better, referring to an appropriate programme of archaeological investigation in the second sentence (but this only relates to locations outside of the Area of Archaeological Importance). The third paragraph should be amended in a similar fashion to the effect that an appropriate programme of archaeological work could consist of evaluation, upfront excavation and/or monitoring by an archaeological contractor.

The final paragraph of the draft policy relates to climate change. While the wording is reasonable, it is not clear from first glance that this is a separate part of the policy (it appears to be part of the archaeology paragraphs). It should be given a separate heading for clarity.

Based on the above issues, we consider the policy is unsound as it is not effective in terms of deliverability against heritage constraints or consistent with national policy which takes a more holistic approach to the historic environment (including paragraphs 126, 156 and 157).