Comment

Representation ID: 24890

Received: 27/10/2017

Respondent: Historic England

Protection of the historic environment should be fully taken into account at all stages and levels of the local planning process. We have produced a number of detailed Good Practice Advice and Advice Note documents. We recommend that you review them as part of your local plan development, alongside our Conservation Principles. In preparation of the forthcoming local plan, we encourage you to draw on the knowledge of local conservation officers, the county archaeologist and local heritage groups. Absence of a comment on an allocation or document in this letter does not mean that Historic England is content with it.

Comment

Representation ID: 24892

Received: 27/10/2017

Respondent: Historic England

We welcome the identification of the high number of heritage assets in Ipswich and Suffolk Coastal in the environmental considerations. However, what this means is not elaborated on. The 2016 Local Authority Profiles note that Ipswich alone has 457 listed buildings, 8 scheduled monuments, 3 registered parks and gardens, and 15 conservation areas. This is a significant number of designated heritage assets in a tightly bounded authority, reflecting Ipswich's long settlement history and historic development. It is not just the high number but also the density and significance of the heritage assets which is key.

Comment

Representation ID: 24895

Received: 27/10/2017

Respondent: Historic England

Ipswich has a rich historic environment and policies should be based on a clear understanding and recognition of the importance of this to the quality and
distinctiveness of the town as a whole. This requires a strong evidence base though any evidence base should be proportionate. However, with a local plan we would expect to see a comprehensive and robust evidence base to support policies. Sources include: National Heritage List for England; Heritage Gateway; Historic Environment Record; heritage at risk registers; locally listed heritage assets; conservation area appraisals; historic characterisation; archaeological assessments; topic papers; (list continues).

Comment

Representation ID: 24896

Received: 27/10/2017

Respondent: Historic England

Further work to improve the evidence base on the Ipswich Waterfront and its connectivity to the town centre. The strategic direction for this area lacks clarity with the layers of the Ipswich Vision, IP-ONE areas and individual site allocations. The relevant conservation area appraisals are notably out of date and the key area of connectivity between them is not covered by a conservation area, despite the significant heritage in the area. See also answer to Question 85.

Comment

Representation ID: 24897

Received: 27/10/2017

Respondent: Historic England

From a historic environment perspective, it is hard to select the preferred option given the range and distribution of heritage assets throughout both the Borough and the district. Each option will have an impact on heritage assets, and it will depend to some extent on where site allocations are identified. We note in particular that in some options Saxmundham and Framlingham have been identified for significant growth. Owing to the concentration of heritage assets and topography, both settlements are sensitive to new development and significant levels of growth are likely to have notable impact on the historic environment.

Comment

Representation ID: 24900

Received: 27/10/2017

Respondent: Historic England

We would note the difference between high density and high rise. Ipswich in particular has had a number of high rise buildings to deliver high density. Historic development patterns also provide high density housing at a low rise level. High density and high rise should not become synonymous. Historic England is commissioning research to better understand how increasing housing density in heritage-rich areas can be achieved in ways sensitive to the historic environment. This will be coming forward during the local plan process and should be considered as part of the evidence base to the local plan.

Comment

Representation ID: 24902

Received: 27/10/2017

Respondent: Historic England

It is important that the historic pattern of settlement in Ipswich and Suffolk Coastal is maintained through a physical separation of settlements, in particular preventing coalescence between Ipswich and the surrounding villages. The issue of coalescence does not just affect larger towns and cities but we have seen proposals in the region proposing coalescence between market towns and villages. Acceptance of such a principal undermines the setting and purpose of each individual settlement and places pressure on numerous heritage assets which lie in the countryside.

Comment

Representation ID: 24908

Received: 27/10/2017

Respondent: Historic England

The town centres in Ipswich and Suffolk Coastal are historic and contain significant concentrations of designated heritage assets. Retailing is changing and that has an impact on the buildings housing them, many of them historic. Each centre is different but consideration needs to be made of whether town centres are sustainable as currently constituted, the usages for buildings are correctly identified and they are adequately protected from harmful change of use or conversion. A planned approach to reinforcing the importance of the town centres as a sustainable location, and consideration of appropriate, alternative or additional uses which will provide a strong future for the buildings, is key. A further consideration is the retention of original/historic or significant shopfronts. A development management policy should be in place to manage their change successfully.

Comment

Representation ID: 24909

Received: 27/10/2017

Respondent: Historic England

The town centres in Ipswich and Suffolk Coastal are historic and contain significant concentrations of designated heritage assets. Retailing is changing and that has an impact on the buildings housing them, many of them historic. Each centre is different but consideration needs to be made of whether town centres are sustainable as currently constituted, the usages for buildings are correctly identified and they are adequately protected from harmful change of use or conversion. A planned approach to reinforcing the importance of the town centres as a sustainable location, and consideration of appropriate, alternative or additional uses which will provide a strong future for the buildings, is key. A further consideration is the retention of original/historic or significant shopfronts. A development management policy should be in place to manage their change successfully.

Comment

Representation ID: 24915

Received: 27/10/2017

Respondent: Historic England

The Landscape Character Assessment and Landscape Sensitivity Study should include heritage assets and their settings, e.g. scheduled monuments, registered parks and gardens, conservation areas. This should prevent the Study identifying an area of land containing, e.g. a scheduled monument to have low sensitivity to development. We also note that design and heritage assessments are planned. Given the historic nature of the district and Borough and the levels of growth proposed, it is likely that heritage impact assessments will be needed for sensitive sites to identify whether/how much development is possible and whether mitigation or enhancement measures can be incorporated.