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

Object

Representation ID: 26654

Received: 02/03/2020

Respondent: Historic England (Historic Buildings and Places)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

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).

Object

Representation ID: 26655

Received: 02/03/2020

Respondent: Historic England (Historic Buildings and Places)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

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).

Object

Representation ID: 26657

Received: 02/03/2020

Respondent: Historic England (Historic Buildings and Places)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

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.

Object

Representation ID: 26658

Received: 02/03/2020

Respondent: Historic England (Historic Buildings and Places)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

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.

Object

Representation ID: 26660

Received: 02/03/2020

Respondent: Historic England (Historic Buildings and Places)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

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.

Object

Representation ID: 26661

Received: 02/03/2020

Respondent: Historic England (Historic Buildings and Places)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

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.

Support

Representation ID: 26666

Received: 02/03/2020

Respondent: Historic England (Historic Buildings and Places)

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

Object

Representation ID: 26667

Received: 02/03/2020

Respondent: Historic England (Historic Buildings and Places)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

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.

Support

Representation ID: 26668

Received: 02/03/2020

Respondent: Historic England (Historic Buildings and Places)

We note the changes to this policy following our Regulation 18 advice.

Support

Representation ID: 26669

Received: 02/03/2020

Respondent: Historic England (Historic Buildings and Places)

We welcome the changes to this policy following our Regulation 18 advice.