Preferred Options Core Strategy and Policies Development Plan Document (DPD) Review

Object

Representation ID: 26043

Received: 13/03/2019

Respondent: Historic England

Note reference to higher density homes but are concerned that it's treated as a synonym for flats. High density doesn't need to take the form of flats (see Increasing Residential Density publication 2018). Request is made clear that high density does not equal flats.

Welcome references to parks and open spaces, built and natural heritage. However, we recommend that the phrase 'built and natural heritage' is amended to 'built, natural and historic environments'. We would like to see a flavour of the town's heritage reflected in the Vision similar to the descriptions for the town's parks and tree canopy.

Support

Representation ID: 26044

Received: 13/03/2019

Respondent: Historic England

We particularly welcome objectives 1 on high standards of design, 5 on enhancing the public realm of the town centre, and 8 about conserving and enhancing the historic environment and landscape character.

Welcome the commitment at 6.10 in principle to regenerate the run down areas close to the historic core.

Object

Representation ID: 26045

Received: 13/03/2019

Respondent: Historic England

The supporting text makes no mention of the inherent sustainability of keeping historic buildings in use.

Object

Representation ID: 26046

Received: 13/03/2019

Respondent: Historic England

The section on densities needs to be clarified. As stated above, high density does not necessarily mean high rise. What does high density mean for the town centre, Portman Quarter and Waterfront? The sentence could also with being broken down into smaller sentences because, as currently constructed, it could be read that the low density elsewhere is so that it does not compromise the heritage assets and the historic character of Ipswich but that this caveat does not apply in the town centre, Portman Quarter, Waterfront and IP-One area.

Object

Representation ID: 26047

Received: 13/03/2019

Respondent: Historic England

Clarity needed within this policy, the Core Strategy and the IP-One section of the Site Allocations Plan of what is the status of the opportunity areas. Paragraph 6.1 of the Site Allocation document sets out - the Opportunity Areas set out development principles for that specific area, which is positive. However, these are not set out in policies, although some areas do have policies within the IP-One section of the document and, again, individual allocation policies take precedence. This doesn't give a consistent vision with clarity for a developer or the ability for the Council to help meet aspirations.

Object

Representation ID: 26048

Received: 13/03/2019

Respondent: Historic England

In para 8.62 we would expect to see the term 'built, historic and natural assets' to be consistent.

We welcome the commitment to a local list in the policy but would suggest that it is turned round '...the maintenance of a list of heritage assets of local importance, such as buildings or parks,....' to make it clear that it is not just buildings that can be included on the list. This should also be supported through the supporting text.

agree that there the area between the Central and Wet Dock Conservation Areas should be reappraised and new boundaries considered.

Object

Representation ID: 26049

Received: 13/03/2019

Respondent: Historic England

Should clarify whether new development includes extensions to historic buildings.

Helpful if supporting text states that when considering sustainable construction and heritage assets that care should be taken to consider both the planning and building regulation implications of proposed interventions in a building. Note that some heritage assets are exempted from compliance requirement with energy efficiency requirements of the Building Regulations where compliance would unacceptably alter their character and appearance and that there are special considerations for others such as those of a traditional construction method which will perform differently.

However, many heritage assets draw on locally sourced building materials.

Object

Representation ID: 26050

Received: 13/03/2019

Respondent: Historic England

We welcome the policy commitment to the special character and distinctiveness
of Ipswich, including significant views. We welcome paragraph 9.12.10 referring developers to the relevant evidence base. We appreciate the wish not to repeat conservation area appraisals etc within the plan but including what this means for Ipswich would make this section more locally specific.

Object

Representation ID: 26051

Received: 13/03/2019

Respondent: Historic England

Recommend that Local List is expanded to cover other types of undesignated heritage assets or where documented in conservation area appraisals it's highlighted in policy terms.

The repetition of the NPPF tests in the second and third paragraphs should be reviewed as they refer to all heritage assets. Wording must be consistent with paragraphs 194, 195, 196, and 197. Alternative is to refer in policy that the tests on harm in the NPPF will be followed.

Grammar error.

Consideration to incorporating requirements in supporting text into policy such as what the requirements are for a heritage statement etc.

Object

Representation ID: 26052

Received: 13/03/2019

Respondent: Historic England

We would expect to see clear provision in policy for non-designated heritage
assets of archaeological interest which are demonstrably of significance to scheduled monuments.