Draft Core Strategy and Policies Focused Review

The vision makes little reference to the historic environment. Given that the NPPF requires local plans to set out a positive strategy for the conservation and enhancement of the historic environment (paragraph 126), it would be sensible for the vision to be strengthened.

As with the vision, we believe that the revised Core Strategy needs to be mindful of the requirements of the NPPF and that the objectives should help contribute towards a positive strategy for the historic environment. While Objective 8 refers to historic buildings and landscape character, this does not incorporate all elements of the historic environment, such as archaeology and townscape character, nor does it refer to the need to seek enhancements to the historic environment.

It is not clear why the key diagram depicts a relatively constrained area within the town centre as "Conservation of the Historic Core", given that the historic core of Ipswich goes beyond this area and includes places such as the Waterfront. It implies that the historic environment beyond this constrained area may not be conserved.

Policy CS2: The Location and Nature of Development
We continue to 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 as this might have negative impacts on heritage assets and wonder whether such a general approach is still justified. The final sentence of Policy CS2 should be reviewed.

The supporting text offers some recognition of the design and conservation issues relating to the location of development, including acknowledgement of the NPPF's requirements in paragraph 8.39. We welcome the reference to the urban characterisation study, which is intended to become an SPD, and look forward to consultation on this document in due course. The findings of this study may need to be reflected within the Core Strategy and other development plan documents.

We note the intention to incorporate the IP-One area into the Site Allocations DPD. This area contains the greatest concentration of heritage assets within the town (both designated and non-designated) and is a location that requires both conservation and change. Part (f) of Policy CS3 requires the AAP to have policies relating to conservation areas, although this should be extended to cover other heritage asset types. Given Part (f), it is disappointing that the draft IP-One AAP in the Site Allocations DPD makes little reference to conservation areas or any other element of the historic environment.

Policy CS4:
While Policy CS4 makes helpful references to the historic environment, we query whether the focused review of the Core Strategy and the draft Site Allocations and Policies DPD pays adequate regard to the requirements of the NPPF. We note that paragraph 4.3.10 of the Sustainability Appraisal report recommends the policies in the Core Strategy are amended to ensure that new development avoids adverse effects on heritage assets.

Paragraph 126 of the NPPF states that: "local planning authorities should set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environment". The NPPF also states that local plans should include strategic policies to deliver the protection and enhancement of the historic environment (paragraph 156) and should identify land where development is inappropriate because of its environmental or historic significance (paragraph 157).

The Ipswich Local Plan as a whole should be able to demonstrate that it sets out a positive strategy for the historic environment. This means that, on balance, the Plan has a positive effect on the historic environment and heritage assets. Different sections of the Plan should form part of the overall positive strategy, such as proposals for housing or employment development. Policies throughout the document should help deliver the conservation of the historic environment with appropriate references where necessary.

English Heritage has produced guidance on how Local Plans should address historic environment issues which can be found online at: www.helm.org.uk/guidance-library/heritage-in-local-plans/.

It would be helpful if this policy and supporting text made reference to the listed buildings that adjoin the urban extension area at Mill Farm and Sparrow's Nest Farm. The Sustainability Appraisal Report picks up on heritage issues (see Table 2 of Appendix E) and makes recommendations for the Core Strategy.

Policy DM5:
We welcome Part (e) of the policy relating to the special character and distinctiveness of Ipswich. The completion of the Urban Characterisation Study would help to support this policy.

Policy DM6:
While we generally welcome the criteria within this policy regarding tall building proposals, it would be helpful to know whether this policy has been reviewed to see whether it remains justified and effective. We maintain that a comprehensive and thoroughly modelled policy is required, as well as a general policy approach on the identification of strategic views. Part (j) of the policy helpfully refers to conservation areas, but it would be strengthened by reference to listed buildings and other heritage assets.

Policy DM8:
While we welcome a specific policy on conservation areas (and buildings of townscape interest), there is a need for Development Management policies that address other designated heritage asset types. As with our comments on Policy CS4, it is insufficient to rely on national policy and legislation for designated heritage assets other than conservation areas. We would wish to see a more inclusive policy approach setting out how planning applications should address a range of heritage assets and issues at the development management stage.

In terms of the current wording of Policy DM8, it is rather brief and only really acts as a policy hook for the Council's Conservation Area Appraisals and Management Plans. While this hook is useful, we believe the policy could go further in terms of offering guidance for development affecting conservation areas (e.g. setting out design issues etc).