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

The development constraints mention the site's location within the Central Conservation Area and area of archaeological importance and the nearby listed buildings and scheduled monument. 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 the site's location within the Stoke Conservation Area (currently on the Heritage at Risk Register) and area of archaeological importance and the nearby listed building. 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 building. 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 adjoining conservation area and archaeology issues, but do not refer to the Grade II listed Church of Holy Trinity 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 building. 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).

Following our response to the 2014 consultation, we welcome the addition of paragraphs relating to the historic environment (5.2, 57 and 5.8). This helps towards meeting Paragraph 126 of the NPPF which requires Local Plans to set out a positive strategy for the historic environment. The IP-One Area is of considerable importance in terms of the historic environment, given that it contains the greatest concentration of the town's designated heritage assets, with a number of important sites and opportunity areas.

It would be helpful if paragraph 5.8 referred to the national Heritage at Risk Register as well as the Council's approach to buildings at risk, as the national register contains more than just listed buildings. It will be important that area and site specific proposals adequately consider impacts on heritage assets (see separate representations).

Our 2014 consultation response noted that the Waterfront area forms part of the town's historic environment and contains a number of important heritage assets including listed buildings and the Wet Dock Conservation Area. It is an area that has undergone much change in the past 15 years and continues to be identified for regeneration opportunities. Given the continued development opportunities and the importance of heritage assets, we sought greater reference to the historic environment. The additional wording in Paragraph 5.16 (last two sentences) is welcomed.

We note that the provision of a new Wet Dock crossing would facilitate access to the Island Site and provide for through traffic, allowing for the calming of the Star Lane Gyratory once completed. We support the principle of calming of the gyratory and the opportunities that provides in terms of stitching the town centre to the waterfront and encouraging the enhancement of heritage assets. However, care will need to be taken with regards to the design of the new crossing, as it passes through the Island Site and the Wet Dock Conservation Area. We welcome the inclusion of a new sentence at the end of paragraph 5.46 which notes the conservation area and requires the crossing to take account of heritage issues.

We welcome the identification of opportunity areas to focus development and regeneration in a coordinated way and the strong link to policy through their reference in Policy CS3. However, the identification of development options in each opportunity area does not always correspond with site allocations and often goes much beyond the boundaries of proposed allocations (e.g. Area B and C). This potentially creates some confusion and needs clarifying. While we welcome the identification of development principles for each opportunity area, this does not overcome the need for the individual site sheets to contain specific development criteria (see separate representations). The key for each diagram shows listed buildings but not scheduled monuments, which is not helpful in terms of clarity.

As currently drafted in relation to opportunity area diagrams, we consider that the plan is unsound as it is not effective or consistent with national policy. The NPPF requires adequate detail to be provided in Local Plans (e.g. paragraphs 154 and 157), while Local Plans should set out a positive strategy for the historic environment (paragraph 126).

This opportunity area is relatively coherent in terms of the sites it covers along the waterfront. References to the historic environment are good, including consideration of archaeology issues. We welcome statements such as maintaining the character of the conservation area and the retention of historic structures. The two diagrams show a number of non-listed buildings in bold outline. The key does not explain what these denote, but it appears to relate to retained buildings. This should be clarified.

This is a more complex and diverse area than Area A, and perhaps less coherent (especially stretching up to the bus station) making it difficult to establish specific development principles relating to specific sites (hence the need for individual site sheets). The area forms an important transition between the town centre and waterfront and needs careful planning to enhance sites and improve links. Design issues such as building heights need consideration and further masterplanning might be useful. Current references to the historic environment are welcomed, but there needs to be greater detail with regards to scheduled monuments and archaeology given the rich potential of this area. Scheduled monuments are not shown in either diagram, with 'development options' mapped over the top of every scheduled monument within this area. This is misleading and does not provide sufficient clarity for development proposals.

As currently drafted in relation to archaeology, we consider that the plan is unsound as it is not effective or consistent with national policy. The NPPF requires adequate detail to be provided in Local Plans (e.g. paragraphs 154 and 157), while Local Plans should set out a positive strategy for the historic environment (paragraph 126).

As with Area B, this is a complex and diverse area in terms of the historic environment. Current references to the historic environment are welcomed, but there needs to be greater detail with regards to scheduled monuments and archaeology. The large scheduled monument that runs through this area is not shown on either diagram, with 'development options' mapped over the top. This is misleading and does not provide sufficient clarity for development proposals.

As currently drafted in relation to archaeology, we consider that the plan is unsound as it is not effective or consistent with national policy. The NPPF requires adequate detail to be provided in Local Plans (e.g. paragraphs 154 and 157), while Local Plans should set out a positive strategy for the historic environment (paragraph 126).