Proposed Submission Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document

Our response to the Core Strategy Review seeks improvements to the vision which would carry forward into this plan. We welcome the reference to Objective 8 under paragraph 3.2, as there is a geographical element to the protection and enhancement of the environment (including heritage assets) that needs to be addressed by this plan.

We have made separate representations on individual sites, but as a general comment, we have concerns regarding a number of sites and their potential impact on the historic environment. While we do not object to the principle of any site allocation, there is sometimes a lack of detail and/or clarity in terms of development constraints and issues in the site sheets contained in Appendix 3. In particular, scheduled monument and archaeological issues are not always properly addressed (see individual sites) in terms of what is required and the implications for potential development schemes. The archaeology of central Ipswich is still in the process of being mapped or understood, but it is a valuable and complex resource given Ipswich's importance as a settlement from the early medieval period onwards. Archaeology could act as a considerable constraint on the deliverability of sites and therefore needs clarity in terms of site-specific requirements (see separate representations). Proposals should acknowledge the archaeological potential of the site and adopt designs which preserve and enhance the historic environment. This could include creative use of open space within development proposals to assist with the preservation of archaeology. Early consultation and assessment is essential to ensue proposals take all aspects of the historic environment into consideration.

Our understanding of Ipswich's archaeology is evolving, which means that additional clarification may be required as the plan progresses towards adoption. 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).

The status of the site sheets in Appendix 3 is not entirely clear. They are described as being "for information only", but they contain lots of detail that is relevant to specific proposals (even if in some cases, the detail is lacking or misleading). Appendix 3 is referred to in supporting paragraphs to each allocation policy (e.g. paragraph 4.8) and again in paragraph 5.7, but there appears to be no obligation to observe the development constraints and issues within the site sheets. We consider that the individual allocation policies should refer to the need to observe the site sheets in Appendix 3. Without these references, the plan is unsound as it is not effective in terms of deliverability against various constraints including heritage, or consistent with national policy.

This site forms part of the approach to/from Whitton Conservation Area and is likely to form part of its setting. Development of 100 homes could have a notable impact on the conservation area, particularly if Site IP032 was also developed for a similar number of homes along with Site 140b for employment. We welcome the publication of a development brief for this and the adjoining site (although we have not had sight of the brief) and the requirement in the site sheet for development to have regard to the conservation area.

This is a very sensitive site where much care will need to be taken to avoid harming the historic environment. In particular, the site contains three scheduled monuments, with considerable archaeological potential across the site. The site also adjoins the Central Conservation Area to the north and west, with the Wet Dock Conservation Area to the south, along with the Grade II* Church of St Mary at the Quay, which are all development issues. 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, 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 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).

The development constraints mentions the area of archaeological importance and the adjoining Central Conservation Area and Grade II* Church of St Clement to the south. However, while the wording explains the implications for development in terms of archaeological matters, there is no explanation of the implications for development in terms of the conservation area and listed church. The lack of clarity could affect proposals for this site. Other sites are clearer in terms of such matters (e.g. IP005).

As currently drafted, we consider the plan to be unsound as the site sheet is not effective or consistent 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).

The development constraints mention the area of archaeological importance, the adjoining Stoke Conservation Area (a conservation area on the Heritage at Risk Register), and the Grade I Church of St Mary at Stoke to the south. However, while the wording explains the implications for development in terms of archaeological matters, there is no explanation of the implications for development in terms of the conservation area and listed church. The lack of clarity could affect proposals for this site. Other sites are clearer in terms of such matters (e.g. IP005).

As currently drafted, we consider the plan to be unsound as the site sheet is not effective or consistent 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).

As with Site IP005, this site falls within the setting of Whitton Conservation Area and could affect its significance, with the risk of cumulative impact. We welcome the publication of a development brief for this and the adjoining site (although we have not had sight of the brief) and the requirement in the site sheet for development to have regard to the conservation area.

This is a very sensitive site, where much care will need to be taken to avoid harming the historic environment. It forms part of the transition area from the town centre to the waterfront, where development needs to reflect this transition in terms of design, scale etc. The site contains a Grade II listed building on College Street, adjoins the Grade I listed and scheduled Wolsey Gate (currently on the Heritage at Risk register) and is located between two conservation areas (Central and Wet Dock) and two Grade II* churches (St Peter's and St Mary at the Quay - the latter is on the Heritage at Risk Register). In terms of archaeology, there are two scheduled monuments to the north (part of the Saxon town) while the site itself was the location of the Priory of St Peter and St Paul and the Cardinal's College. 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 many of the above heritage assets, 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 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 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).

The Island Site forms a large part of the Wet Dock Conservation Area and contributes to the significance of this heritage asset. We welcome the wording in the development constraints regarding the retention and refurbishment of historic structures and the reference to archaeology including industrial heritage. The wording also helpfully refers to the principles contained within Opportunity Area A (which we broadly support).

The development constraints refer to archaeology and the adjoining listed building and conservation area and refer to the development principles contained within Opportunity Area A. However, while the wording explains the implications for development in terms of archaeological matters, there is no explanation of the implications for development in terms of the conservation area and listed church. The lack of clarity could affect proposals for this site. Other sites are clearer in terms of such matters (e.g. IP005).

As currently drafted, we consider the plan to be unsound as the site sheet is not effective or consistent 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).