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

The development constraints mention archaeology (if not the area of archaeological importance with covers over half of the site), and the nearby Central and Burlington Road Conservation Areas and the Grade II* Church of St Matthew to the west. Reference is also made to the development principles contained within Opportunity Area E. 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 areas 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).

This is a very sensitive site partly within the Central Conservation Area and containing Grade II listed buildings while adjoining other listed buildings, including the Grade II* 54-58 Fore Street to the north-east, the Grade II* Old Custom House to the south-west and the complex of highly graded listed buildings to the south-east at Isaac Lord. The archaeological issues include the Jewish Burial Ground, which appears to be excluded from the site allocation but could still be affected, plus archaeological potential across other parts of the site. The exclusion of the burial ground raises questions about how any redevelopment would respect this heritage asset in terms of its significance and setting. 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 consideration. 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 in terms of archaeology. There could be nationally important archaeology within the site where development may not be appropriate. The revised site sheet should also be strengthened with regards to its wording on the conservation area and listed buildings, and better linked to national policy wording. Clarity is also needed regarding the burial ground.

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).

This is a very sensitive site, where approximately half of the site is designated as a scheduled monument (part of the Saxon town) and there is considerable archaeological potential across the whole site. The site also adjoins the Central Conservation Area to the south and listed buildings to the south and east, with a locally listed façade along Carr Street. 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 (and helpfully refers to the need to retain the locally listed façade on Carr Street), the wording 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. 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 mention the area of archaeological importance, the adjoining Central Conservation Area and nearby scheduled monuments, but only refers to the Grade II* listed building to the north when there is also a Grade II building (26-28 Fore Street). 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 areas and listed buildings. 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).

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).

The development constraints mention the area of archaeological importance, the part location within the (Central) conservation area and adjacent listed building (although there is more than one listed building in the vicinity). 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 buildings. 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 archaeology and the adjoining (Burlington Road) conservation area. 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. 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).

We note this site is now proposed for allocation following the lapse of planning permission. The site adjoins the Wet Dock Conservation Area and the Grade II listed building of 42-48 Felaw Street, and is within the area of archaeological importance. While the development constrains refer to the area of archaeological importance, there is no reference to the conservation area or listed building, or what the implications are for development. The lack of clarity could affect proposals for this site, notwithstanding the reference to the development principles set out in Opportunity Area A.

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).

IP136: College Street
This is a sensitive site within the Central and West Dock Conservation Areas and opposite the Grade I listed and scheduled Wolsey Gate, plus sits within the area of archaeological importance. The development constraints mention these heritage assets, but apart from archaeology, there is no explanation of the implications for specific proposals with regards to the conservation area and listed/scheduled gate. 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 Sites IP005 and IP032, this site falls within the setting of Whitton Conservation Area and could affect its significance, with the risk of cumulative impact. The conservation area is not mentioned in the development constraints (although archaeology is). The lack of clarity could affect proposals for this site, and is not consistent with the wording used in the site sheets for IP005 and IP032.

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).