Post Submission Main Modifications Core Strategy and Policies (DPD) and Site Allocations and Policies (incorporating IP-One Area Action Plan) (DPD)

Object

Representation ID: 24421

Received: 29/12/2016

Respondent: Historic England

Legally compliant? Not specified

Sound? Not specified

In respect of the modifications to Policy CS2, we would reiterate our comments made on 5 March 2015 that 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 wording regarding heritage assets and the historic character of Ipswich in the amended paragraph at the end of the policy.

Object

Representation ID: 24422

Received: 29/12/2016

Respondent: Historic England

Legally compliant? Not specified

Sound? Not specified

CS4 We welcome the amendments to the supporting text of Policy CS4 as set out, as documented in our Statement of Common Ground. Regarding the new amendment to paragraph 8.55, we would recommend amending it to read: "Decisions about proposed development which would harm the significance of a heritage asset will be taken having regard to the NPPF." This is to ensure all relevant paragraphs of the NPPF are taken into account and also as the requirements in paragraph 133 in particular are not a 'balancing exercise' but specify that the public benefits have to be substantial and outweigh the harm or loss. We would note that whilst paragraph 8.55 is primarily concerned with Registered Parks and Gardens as a designated heritage asset, the decision making addition should reflect that not all heritage assets of all types are designated. As a general point we note that throughout these modifications reference is made to the `National Planning Practice Guidance' when it is usually referred to as the Planning Practice Guidance.

Support

Representation ID: 24423

Received: 29/12/2016

Respondent: Historic England

CS11 Further to our representations made on 5 March 2015, we welcome the amendment to: "heritage assets including their setting" of criteria c. iv. of Policy CS11.

Object

Representation ID: 24424

Received: 29/12/2016

Respondent: Historic England

Legally compliant? Not specified

Sound? Not specified

DM5 In respect of the addition to paragraph 9.49 supporting text we recommend that this is amended to: "Decisions about proposed development which would harm the significance of a heritage asset will be taken having regard to the NPPF." This is to ensure that all relevant paragraphs of the NPPF are taken into account, including paragraph 135 relating to non-designated heritage assets. We also would note that the requirements in paragraph 133 in particular are not a 'balancing exercise' but specify that the public benefits have to be substantial and outweigh the harm or loss.

Object

Representation ID: 24426

Received: 29/12/2016

Respondent: Historic England

Legally compliant? Not specified

Sound? Not specified

DM6 We would recommend the same amendments to the changes proposed to paragraph 9.61: "Decisions about proposed development which would harm the significance of a heritage asset will be taken having regard to the NPPF." This is to ensure that all relevant paragraphs of the NPPF are taken into account, including paragraph 135 relating to non-designated heritage assets. We also would note that the requirements in paragraph 133 in particular are not a 'balancing exercise' but specify that the public benefits have to be substantial and outweigh the harm or loss.

Object

Representation ID: 24427

Received: 29/12/2016

Respondent: Historic England

Legally compliant? Not specified

Sound? Not specified

DM8 We welcome the amendments to Policy DM8 and the supporting text as set out, as documented in our Statement of Common Ground. Subject to our general point above, we note a typographical error in paragraph 9.71 where the National Planning Practice Guidance has a lower case 'n'. In respect of paragraph 9.72 we would recommend the same amendments to the changes proposed above: "Decisions about proposed development which would harm the significance of a heritage asset will be taken having regard to the NPPF." This is to ensure that all relevant paragraphs of the NPPF are taken into account, including paragraph 135 relating to non-designated heritage assets. We also would note that the requirements in paragraph 133 in particular are not a 'balancing exercise' but specify that the public benefits have to be substantial and outweigh the harm or loss.

Object

Representation ID: 24428

Received: 29/12/2016

Respondent: Historic England

Legally compliant? Not specified

Sound? Not specified

DM9 We note the amendments made to Policy DM9.

Object

Representation ID: 24430

Received: 29/12/2016

Respondent: Historic England

Legally compliant? Not specified

Sound? Not specified

Appendix 7 Glossary We welcome the inclusion of definitions of heritage designations as set out in our Statement of Common Ground. We believe there may be a typographical error in the first line of the Conservation Area definition where 'with' should be 'within'? In addition, we would suggest noting, as has been done with the scheduled monument definition, that conservation areas and registered parks and gardens are designated heritage assets, for consistency purposes. We also would suggest referring to paragraph 139 of the NPPF in respect of Areas of Archaeological Importance which states: "non-designated heritage assets of archaeological interest that are demonstrably of equivalent significance to scheduled monuments, should be considered subject to the policies for designated heritage assets."

Support

Representation ID: 24445

Received: 29/11/2016

Respondent: Historic England

support adding Scheduled Ancient Monuments to the key

Support

Representation ID: 24446

Received: 29/11/2016

Respondent: Historic England

Support suggested changes identified to site analysis and development options plans to remove buildings shown with a bold outline and amend the development opportunities guidance to delete 'max' re residential (50%) could live in live-work units