Core Strategy and Policies DPD Review - Pre-Submission of Main Modifications

We welcome the proposed main modification to Policy CS4, which largely addresses our concerns with the Proposed Submission draft. Although the additional wording to the third sentence does not fully reflect our suggested wording, the modification does enough to overcome our concerns. Amending 'historical' to 'heritage' in the first sentence is also welcomed.

While it does not form part of the current public consultation, we note and welcome the additional modification to paragraph 8.46 which clarifies the council's local and strategic approach to listed buildings, addressing our concerns with the Proposed Submission draft. We also welcome the deletion of the second sentence to paragraph 8.53, which addresses our concerns, and the additional reference to the proposed Ipswich Urban Archaeological Database. Finally, we welcome the additional wording to paragraph 8.55 which addresses our concerns and uses our suggested text relating to registered parks and gardens.

We support the proposed main modification which adds reference to the setting of listed buildings to Part (e) of the policy.

We support the proposed main modification which adds reference to listed buildings and other heritage assets into clause (j). This addresses our concerns regarding the wording of this policy.

We note the various proposed main modifications to Policy DM8 responding to the objections of Historic England and Suffolk County Council. Re-labelling Part (a) as 'designated and un-designated assets' and adding a third and fourth paragraph is helpful in terms of covering other heritage asset types and the issue of demolition. It provides the minimum required text to address our concerns, although in the new fourth paragraph, parks and gardens are 'registered', not 'scheduled'. Additional text on registered parks and gardens in the supporting paragraphs would be helpful. In paragraph 9.71, the Practice Guide to PPS5 has been withdrawn and replaced with Historic England Good Practice Advice Notes (see: www.historicengland.org.uk/advice/planning/planning-system/).

We welcome the modification to Part (b) in terms of point (i) which clarifies that a building/structure can be demolished if it does not make a positive contribution to the significance of the conservation area.

We have concerns regarding the proposed main modifications to the archaeology paragraphs in Part (c) in terms of the deleted reference to the Area of Archaeological Importance (AAI). Removing reference to the AAI means that there is no policy guidance as to what the AAI means in terms of development proposals. The AAI is identified on the Policies Map (Plan 4) and covers the central area of Ipswich where archaeology is likely to be the most important. We consider this modification to be unsound as it not effective in terms of delivering the plan. It does not provide sufficient clarity regarding the status of the AAI.

Other proposed main modifications to Part (c) seek to address our concerns with the Proposed Submission draft by removing reference to only monitoring works. The modifications also attempt to respond to the representations of Suffolk County Council, but do not reflect all of the county council's suggestions.

While it does not form part of the current public consultation, we note the additional modification to paragraph 9.73 which addresses the representation of Suffolk County Council but also introduces wording regarding archaeology and planning. We also note the additional modification to paragraph 9.74 which seeks to clarify the purpose of the AAI, but does not justify the deletion of references to the AAI in the policy itself.