Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

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Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Chapter 6 - Vision and Objectives

Representation ID: 26654

Received: 02/03/2020

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Under paragraph 35 of the National Planning Policy Framework (‘The Framework’) we consider that this Plan is unsound as some aspects are not effective, or consistent with national policy. We have identified in detail below where we find the Plan unsound and what measures are needed to make the Plan sound. In particular we have recommended the inclusion of specific policy references for heritage assets and identified mitigation within Policies SP2 (Land Allocated for Housing), SP4 (Opportunity Sites), SP5 (Land Allocated for Employment Use), SP11 (The Waterfront), SP12 (Education Quarter), and SP13 (Portman Quarter).

Change suggested by respondent:

Not specified

Attachments:

2571 - Scanned Representation (408.00 KB)

Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Policy CS2 The Location and Nature of Development

Representation ID: 26655

Received: 02/03/2020

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Concerned that 'higher density homes' is a synonym for tall buildings/ flats. Appears to be confirmed in final paragraph of Policy. Inference that ‘high density’ could ‘compromise’ the historic character of Ipswich, by way of tall buildings affecting the setting of these assets, impacting on their significance. Consider this section on densities needs to be clarified, and ‘high’, ‘medium’ and ‘low’ densities defined. Should also make clear that good design should not only respect the historic character of an area, but respond to it. High density does not need to take the form of flats, see‘Increasing Residential Density publication (2018).

Change suggested by respondent:

Section on densities needs to be clarified, and ‘high’, ‘medium’ and ‘low’ densities defined. Should also make clear that good design should not only respect the historic character of an area, but respond to it.

Attachments:

2571 - Scanned Representation (408.00 KB)

Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Policy CS3 IP-One Area Action Plan

Representation ID: 26657

Received: 02/03/2020

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Extremely concerned about the following key aspects:
1. The lack of clarity regarding the status of the IP-One Area Action Plan;
2. The lack of clear delineation of the opportunity areas; and
3. The absence of robust policies for these which in our view renders this aspect of the Plan not effective, and therefore unsound.
See detailed commentary for further explanation of these concerns. Ipswich has a high number of historic assets in the IP-One area and appropriate management of the historic environment will therefore be a significant consideration in the design and deliverability of new development.

Change suggested by respondent:

If the IP-One Area Action Plan has been completed then Policy CS3 and supporting text need to clearly state this. Opportunity areas need to be clearly defined and labelled on the policies map, so that it is clear which policy and supporting text relates to which area, and the extent of the land in question. Recommended one policy for each opportunity area which specifically sets out the main criteria and parameters for that land. Robust site specific policies will help to articulate the vision for each opportunity area, setting out the means to improve connectivity, legibility, and ones experience of historic places, and help to ensure the key design and heritage principles are employed consistently and to a high quality. Review the wording for policies SP2, SP4, SP5, SP11, SP12, and SP13 identifying which heritage assets (or their settings) would be affected by the proposed development. Elevate the Development Options plans (i.e. those illustrating the development options and design guidelines) from chapter 6 into the policies.

Attachments:

2571 - Scanned Representation (408.00 KB)

Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Policy ISPA4 Cross Boundary Working to Deliver Sites

Representation ID: 26658

Received: 02/03/2020

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Site includes Grade II Listed Everton School Westerfield House, and adjacent to/within the setting of other Grade II Listed buildings (Allens House, and Laceys Farmhouse). Development must preserve and where possible enhance these assets and their settings where this setting contributes to significance. Heritage Impact Assessment required, which must assess the contribution this land makes to those elements which contribute towards the significance of the heritage assets (designated and non-designated), and determine what impact its development might have upon their significance. Any specific measures required to remove/ mitigate any harm should be included in a site specific policy for ISPA4.1.

Change suggested by respondent:

Heritage Impact Assessment of ISPA4.1 required. Any specific measures required from the assessment then integrated into a site specific policy.

Attachments:

2571 - Scanned Representation (408.00 KB)

Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Policy CS3 IP-One Area Action Plan

Representation ID: 26660

Received: 02/03/2020

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The way the IP-one area action plan is referred to suggests that this work has yet to be completed, and that in due course a new Area Action Plan will be prepared, clarifying the opportunity area boundaries, and setting out detailed policy criteria. However, this is not clear and is confusing and misleading. Concern is that the Plan should be readable and useable for everyone. If the IP-One Area Action Plan has been completed and is incorporated, then Policy and supporting text need to clearly state this. Notwithstanding this, it is our contention that the Council has not followed CS3.

Change suggested by respondent:

Policy requires clarification as to the status of the IP-One Area Action Plan.

Attachments:

2571 - Scanned Representation (408.00 KB)

Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Chapter 7 - Key Diagram

Representation ID: 26661

Received: 02/03/2020

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Regarding the delineation of the opportunity areas, it is unclear which boundaries the Council is promoting through this Plan, and which areas are covered by Policies SP11, SP12, and SP13. The Policies Map IP-One Area inset and Chapter 6 of the Plan shows detailed boundaries for eight opportunity areas. However, these areas do not match up with illustrative boundaries in The Ipswich Key Diagram. The opportunity areas need to be clearly defined and labelled on the policies map, so that it is clear which policy and supporting text relates to which area, and the extent of the land in question.

Change suggested by respondent:

The opportunity areas need to be clearly defined and labelled on the policies map.

Attachments:

2571 - Scanned Representation (408.00 KB)

Support

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Policy CS4 Protecting our Assets

Representation ID: 26666

Received: 02/03/2020

Respondent: Historic England

Representation Summary:

We welcome the changes to criterion 3 regarding the Council’s commitment to a local list in policy.

Change suggested by respondent:

N/A

Attachments:

2571 - Scanned Representation (408.00 KB)

Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Policy DM15 Tall Buildings

Representation ID: 26667

Received: 02/03/2020

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Support changes to Policy DM15, but request criterion ‘i’ is amended. Remain concerned that the tall building arc still includes a significant area within the setting of the Grade I Listed Willis Building. One of its most striking features is its curvilinear glass curtain walling that reflects the surrounding buildings. Any new tall building therefore has the potential to impact on the setting, and therefore significance of this important building, and on this basis we advise pulling back the arc boundary in the immediate vicinity. Our Tall buildings advice note provides more information.

Change suggested by respondent:

Amend criterion 'i' as follows; "Preserves strategic and local views, with particular reference to the settings of conservation areas, listed buildings, scheduled monuments, and other heritage assets, and the wooded skyline visible from and towards central Ipswich." Pull back the tall building arc on the IP-One policies map.