Southend Central Area Action Plan & Proposals Map - Proposed Submission

As a general point, we are pleased to see that heritage has been integrated into the plan throughout the various chapters. We do not have any over-riding concerns in relation to the plan that would raise questions of soundness. Notwithstanding this, we would like to make some suggestions for minor amendments, for your consideration. These are outlined below together with other general comments which we hope you will find useful.

Open Space and the environment. We welcome the discussion of green and civic spaces and their identification in the preceding 6.3.1. A number of these spaces are within conservation areas, however another important feature are the street trees, which survive especially in Cliff Town.

We support the principles of the Public Realm Enhancements, especially the reduction of clutter. The sea front is an area that would benefit greatly, but its function as a busy traffic route requires imaginative thinking if the pedestrian is to be able to reclaim priority. Historic precedents could inform the materials and street furniture where evidence survives (as an example, the finial street name signs that were once a feature of the town). Areas of surviving original paving should be retained and augmented.

English Heritage supports the protection of visually active frontages and introduction of new elements especially from the Royals Centre onto Pier Hill.

We are pleased to see the emphasis on protection of visually important views.

English Heritage supports the Landmark Buildings policy with the important caveats relating to protection of existing landmarks as included in the schedule in Appendix 4. We are pleased to see inclusion of the Pier in the schedule, although, presumably by oversight this has been omitted on the Proposals Map.

In discussing conservation areas, we are disappointed that there is no commitment to appraise these areas on a regular basis and to review some of the boundary anomalies, such as the east boundary of Cliff Town. This reiterates previous advice that English Heritage included in our letter of 5 August 2010, when in commenting on the Issues and Options consultation for the Central Area Action Plan we commented "that in order to fully understand and address change in this area more investigative work needs to be carried out. Our Conservation Principles, Policy and Guidance emphasises (para 62 onwards) the need to understand the fabric and evolution of a place and to identify who values the place and why they do so. Paragraph 89 underlines the value of specific investigation into understanding the impacts, or consequences, of proposed change".

Nonetheless English Heritage welcomes your document's strong emphasis on the role of heritage in the distinctive character of the town centre. We are pleased to see that it has become a strong theme in specific policies especially those relating to High Street and Central Sea Front where the value of heritage-led regeneration has not always been acknowledged in the recent past. We would support all the policies and add only these additional comments.

Clifftown. We support these proposals but recommend a stronger heritage strategy to include assessment of buildings for local listing and extension of the conservation area designation.

Frontages of Townscape Merit. We commend this concept, especially in streets outside the conservation areas, notably High Street. This responds to our previous concerns on undesignated assets such as the former Keddies Store. We welcome the emphasis on shop fronts but would add that we consider it essential to acknowledge the importance of roofscape as part of the overall building frontage.

While we welcome the consideration given to archaeology we consider following minor amendments would be appropriate:

For clarity, none of the above comments should be taken as formal objections to the soundness of the Area Action Plan. We would, however, hope that you may be able to give the recommended changes, highlighted above, your consideration as minor amendments to the plan.

As a general point, we are pleased to see that heritage has been integrated into the plan throughout the various chapters. We do not have any over-riding concerns in relation to the plan that would raise questions of soundness. Notwithstanding this, we would like to make some suggestions for minor amendments, for your consideration. These are outlined below together with other general comments which we hope you will find useful.

Open Space and the environment. We welcome the discussion of green and civic spaces and their identification in the preceding 6.3.1. A number of these spaces are within conservation areas, however another important feature are the street trees, which survive especially in Cliff Town.

We support the principles of the Public Realm Enhancements, especially the reduction of clutter. The sea front is an area that would benefit greatly, but its function as a busy traffic route requires imaginative thinking if the pedestrian is to be able to reclaim priority. Historic precedents could inform the materials and street furniture where evidence survives (as an example, the finial street name signs that were once a feature of the town). Areas of surviving original paving should be retained and augmented.

English Heritage supports the protection of visually active frontages and introduction of new elements especially from the Royals Centre onto Pier Hill.

We are pleased to see the emphasis on protection of visually important views.

English Heritage supports the Landmark Buildings policy with the important caveats relating to protection of existing landmarks as included in the schedule in Appendix 4. We are pleased to see inclusion of the Pier in the schedule, although, presumably by oversight this has been omitted on the Proposals Map.

In discussing conservation areas, we are disappointed that there is no commitment to appraise these areas on a regular basis and to review some of the boundary anomalies, such as the east boundary of Cliff Town. This reiterates previous advice that English Heritage included in our letter of 5 August 2010, when in commenting on the Issues and Options consultation for the Central Area Action Plan we commented "that in order to fully understand and address change in this area more investigative work needs to be carried out. Our Conservation Principles, Policy and Guidance emphasises (para 62 onwards) the need to understand the fabric and evolution of a place and to identify who values the place and why they do so. Paragraph 89 underlines the value of specific investigation into understanding the impacts, or consequences, of proposed change".

Nonetheless English Heritage welcomes your document's strong emphasis on the role of heritage in the distinctive character of the town centre. We are pleased to see that it has become a strong theme in specific policies especially those relating to High Street and Central Sea Front where the value of heritage-led regeneration has not always been acknowledged in the recent past. We would support all the policies and add only these additional comments.

Clifftown. We support these proposals but recommend a stronger heritage strategy to include assessment of buildings for local listing and extension of the conservation area designation.

Frontages of Townscape Merit. We commend this concept, especially in streets outside the conservation areas, notably High Street. This responds to our previous concerns on undesignated assets such as the former Keddies Store. We welcome the emphasis on shop fronts but would add that we consider it essential to acknowledge the importance of roofscape as part of the overall building frontage.

While we welcome the consideration given to archaeology we consider following minor amendments would be appropriate:

For clarity, none of the above comments should be taken as formal objections to the soundness of the Area Action Plan. We would, however, hope that you may be able to give the recommended changes, highlighted above, your consideration as minor amendments to the plan.

As a general point, we are pleased to see that heritage has been integrated into the plan throughout the various chapters. We do not have any over-riding concerns in relation to the plan that would raise questions of soundness. Notwithstanding this, we would like to make some suggestions for minor amendments, for your consideration. These are outlined below together with other general comments which we hope you will find useful.

Open Space and the environment. We welcome the discussion of green and civic spaces and their identification in the preceding 6.3.1. A number of these spaces are within conservation areas, however another important feature are the street trees, which survive especially in Cliff Town.

We support the principles of the Public Realm Enhancements, especially the reduction of clutter. The sea front is an area that would benefit greatly, but its function as a busy traffic route requires imaginative thinking if the pedestrian is to be able to reclaim priority. Historic precedents could inform the materials and street furniture where evidence survives (as an example, the finial street name signs that were once a feature of the town). Areas of surviving original paving should be retained and augmented.

English Heritage supports the protection of visually active frontages and introduction of new elements especially from the Royals Centre onto Pier Hill.

We are pleased to see the emphasis on protection of visually important views.

English Heritage supports the Landmark Buildings policy with the important caveats relating to protection of existing landmarks as included in the schedule in Appendix 4. We are pleased to see inclusion of the Pier in the schedule, although, presumably by oversight this has been omitted on the Proposals Map.

In discussing conservation areas, we are disappointed that there is no commitment to appraise these areas on a regular basis and to review some of the boundary anomalies, such as the east boundary of Cliff Town. This reiterates previous advice that English Heritage included in our letter of 5 August 2010, when in commenting on the Issues and Options consultation for the Central Area Action Plan we commented "that in order to fully understand and address change in this area more investigative work needs to be carried out. Our Conservation Principles, Policy and Guidance emphasises (para 62 onwards) the need to understand the fabric and evolution of a place and to identify who values the place and why they do so. Paragraph 89 underlines the value of specific investigation into understanding the impacts, or consequences, of proposed change".

Nonetheless English Heritage welcomes your document's strong emphasis on the role of heritage in the distinctive character of the town centre. We are pleased to see that it has become a strong theme in specific policies especially those relating to High Street and Central Sea Front where the value of heritage-led regeneration has not always been acknowledged in the recent past. We would support all the policies and add only these additional comments.

Clifftown. We support these proposals but recommend a stronger heritage strategy to include assessment of buildings for local listing and extension of the conservation area designation.

Frontages of Townscape Merit. We commend this concept, especially in streets outside the conservation areas, notably High Street. This responds to our previous concerns on undesignated assets such as the former Keddies Store. We welcome the emphasis on shop fronts but would add that we consider it essential to acknowledge the importance of roofscape as part of the overall building frontage.

While we welcome the consideration given to archaeology we consider following minor amendments would be appropriate:

For clarity, none of the above comments should be taken as formal objections to the soundness of the Area Action Plan. We would, however, hope that you may be able to give the recommended changes, highlighted above, your consideration as minor amendments to the plan.

As a general point, we are pleased to see that heritage has been integrated into the plan throughout the various chapters. We do not have any over-riding concerns in relation to the plan that would raise questions of soundness. Notwithstanding this, we would like to make some suggestions for minor amendments, for your consideration. These are outlined below together with other general comments which we hope you will find useful.

Open Space and the environment. We welcome the discussion of green and civic spaces and their identification in the preceding 6.3.1. A number of these spaces are within conservation areas, however another important feature are the street trees, which survive especially in Cliff Town.

We support the principles of the Public Realm Enhancements, especially the reduction of clutter. The sea front is an area that would benefit greatly, but its function as a busy traffic route requires imaginative thinking if the pedestrian is to be able to reclaim priority. Historic precedents could inform the materials and street furniture where evidence survives (as an example, the finial street name signs that were once a feature of the town). Areas of surviving original paving should be retained and augmented.

English Heritage supports the protection of visually active frontages and introduction of new elements especially from the Royals Centre onto Pier Hill.

We are pleased to see the emphasis on protection of visually important views.

English Heritage supports the Landmark Buildings policy with the important caveats relating to protection of existing landmarks as included in the schedule in Appendix 4. We are pleased to see inclusion of the Pier in the schedule, although, presumably by oversight this has been omitted on the Proposals Map.

In discussing conservation areas, we are disappointed that there is no commitment to appraise these areas on a regular basis and to review some of the boundary anomalies, such as the east boundary of Cliff Town. This reiterates previous advice that English Heritage included in our letter of 5 August 2010, when in commenting on the Issues and Options consultation for the Central Area Action Plan we commented "that in order to fully understand and address change in this area more investigative work needs to be carried out. Our Conservation Principles, Policy and Guidance emphasises (para 62 onwards) the need to understand the fabric and evolution of a place and to identify who values the place and why they do so. Paragraph 89 underlines the value of specific investigation into understanding the impacts, or consequences, of proposed change".

Nonetheless English Heritage welcomes your document's strong emphasis on the role of heritage in the distinctive character of the town centre. We are pleased to see that it has become a strong theme in specific policies especially those relating to High Street and Central Sea Front where the value of heritage-led regeneration has not always been acknowledged in the recent past. We would support all the policies and add only these additional comments.

Clifftown. We support these proposals but recommend a stronger heritage strategy to include assessment of buildings for local listing and extension of the conservation area designation.

Frontages of Townscape Merit. We commend this concept, especially in streets outside the conservation areas, notably High Street. This responds to our previous concerns on undesignated assets such as the former Keddies Store. We welcome the emphasis on shop fronts but would add that we consider it essential to acknowledge the importance of roofscape as part of the overall building frontage.

While we welcome the consideration given to archaeology we consider following minor amendments would be appropriate:

For clarity, none of the above comments should be taken as formal objections to the soundness of the Area Action Plan. We would, however, hope that you may be able to give the recommended changes, highlighted above, your consideration as minor amendments to the plan.

As a general point, we are pleased to see that heritage has been integrated into the plan throughout the various chapters. We do not have any over-riding concerns in relation to the plan that would raise questions of soundness. Notwithstanding this, we would like to make some suggestions for minor amendments, for your consideration. These are outlined below together with other general comments which we hope you will find useful.

Open Space and the environment. We welcome the discussion of green and civic spaces and their identification in the preceding 6.3.1. A number of these spaces are within conservation areas, however another important feature are the street trees, which survive especially in Cliff Town.

We support the principles of the Public Realm Enhancements, especially the reduction of clutter. The sea front is an area that would benefit greatly, but its function as a busy traffic route requires imaginative thinking if the pedestrian is to be able to reclaim priority. Historic precedents could inform the materials and street furniture where evidence survives (as an example, the finial street name signs that were once a feature of the town). Areas of surviving original paving should be retained and augmented.

English Heritage supports the protection of visually active frontages and introduction of new elements especially from the Royals Centre onto Pier Hill.

We are pleased to see the emphasis on protection of visually important views.

English Heritage supports the Landmark Buildings policy with the important caveats relating to protection of existing landmarks as included in the schedule in Appendix 4. We are pleased to see inclusion of the Pier in the schedule, although, presumably by oversight this has been omitted on the Proposals Map.

In discussing conservation areas, we are disappointed that there is no commitment to appraise these areas on a regular basis and to review some of the boundary anomalies, such as the east boundary of Cliff Town. This reiterates previous advice that English Heritage included in our letter of 5 August 2010, when in commenting on the Issues and Options consultation for the Central Area Action Plan we commented "that in order to fully understand and address change in this area more investigative work needs to be carried out. Our Conservation Principles, Policy and Guidance emphasises (para 62 onwards) the need to understand the fabric and evolution of a place and to identify who values the place and why they do so. Paragraph 89 underlines the value of specific investigation into understanding the impacts, or consequences, of proposed change".

Nonetheless English Heritage welcomes your document's strong emphasis on the role of heritage in the distinctive character of the town centre. We are pleased to see that it has become a strong theme in specific policies especially those relating to High Street and Central Sea Front where the value of heritage-led regeneration has not always been acknowledged in the recent past. We would support all the policies and add only these additional comments.

Clifftown. We support these proposals but recommend a stronger heritage strategy to include assessment of buildings for local listing and extension of the conservation area designation.

Frontages of Townscape Merit. We commend this concept, especially in streets outside the conservation areas, notably High Street. This responds to our previous concerns on undesignated assets such as the former Keddies Store. We welcome the emphasis on shop fronts but would add that we consider it essential to acknowledge the importance of roofscape as part of the overall building frontage.

While we welcome the consideration given to archaeology we consider following minor amendments would be appropriate:

For clarity, none of the above comments should be taken as formal objections to the soundness of the Area Action Plan. We would, however, hope that you may be able to give the recommended changes, highlighted above, your consideration as minor amendments to the plan.

As a general point, we are pleased to see that heritage has been integrated into the plan throughout the various chapters. We do not have any over-riding concerns in relation to the plan that would raise questions of soundness. Notwithstanding this, we would like to make some suggestions for minor amendments, for your consideration. These are outlined below together with other general comments which we hope you will find useful.

Open Space and the environment. We welcome the discussion of green and civic spaces and their identification in the preceding 6.3.1. A number of these spaces are within conservation areas, however another important feature are the street trees, which survive especially in Cliff Town.

We support the principles of the Public Realm Enhancements, especially the reduction of clutter. The sea front is an area that would benefit greatly, but its function as a busy traffic route requires imaginative thinking if the pedestrian is to be able to reclaim priority. Historic precedents could inform the materials and street furniture where evidence survives (as an example, the finial street name signs that were once a feature of the town). Areas of surviving original paving should be retained and augmented.

English Heritage supports the protection of visually active frontages and introduction of new elements especially from the Royals Centre onto Pier Hill.

We are pleased to see the emphasis on protection of visually important views.

English Heritage supports the Landmark Buildings policy with the important caveats relating to protection of existing landmarks as included in the schedule in Appendix 4. We are pleased to see inclusion of the Pier in the schedule, although, presumably by oversight this has been omitted on the Proposals Map.

In discussing conservation areas, we are disappointed that there is no commitment to appraise these areas on a regular basis and to review some of the boundary anomalies, such as the east boundary of Cliff Town. This reiterates previous advice that English Heritage included in our letter of 5 August 2010, when in commenting on the Issues and Options consultation for the Central Area Action Plan we commented "that in order to fully understand and address change in this area more investigative work needs to be carried out. Our Conservation Principles, Policy and Guidance emphasises (para 62 onwards) the need to understand the fabric and evolution of a place and to identify who values the place and why they do so. Paragraph 89 underlines the value of specific investigation into understanding the impacts, or consequences, of proposed change".

Nonetheless English Heritage welcomes your document's strong emphasis on the role of heritage in the distinctive character of the town centre. We are pleased to see that it has become a strong theme in specific policies especially those relating to High Street and Central Sea Front where the value of heritage-led regeneration has not always been acknowledged in the recent past. We would support all the policies and add only these additional comments.

Clifftown. We support these proposals but recommend a stronger heritage strategy to include assessment of buildings for local listing and extension of the conservation area designation.

Frontages of Townscape Merit. We commend this concept, especially in streets outside the conservation areas, notably High Street. This responds to our previous concerns on undesignated assets such as the former Keddies Store. We welcome the emphasis on shop fronts but would add that we consider it essential to acknowledge the importance of roofscape as part of the overall building frontage.

While we welcome the consideration given to archaeology we consider following minor amendments would be appropriate:

For clarity, none of the above comments should be taken as formal objections to the soundness of the Area Action Plan. We would, however, hope that you may be able to give the recommended changes, highlighted above, your consideration as minor amendments to the plan.

As a general point, we are pleased to see that heritage has been integrated into the plan throughout the various chapters. We do not have any over-riding concerns in relation to the plan that would raise questions of soundness. Notwithstanding this, we would like to make some suggestions for minor amendments, for your consideration. These are outlined below together with other general comments which we hope you will find useful.

Open Space and the environment. We welcome the discussion of green and civic spaces and their identification in the preceding 6.3.1. A number of these spaces are within conservation areas, however another important feature are the street trees, which survive especially in Cliff Town.

We support the principles of the Public Realm Enhancements, especially the reduction of clutter. The sea front is an area that would benefit greatly, but its function as a busy traffic route requires imaginative thinking if the pedestrian is to be able to reclaim priority. Historic precedents could inform the materials and street furniture where evidence survives (as an example, the finial street name signs that were once a feature of the town). Areas of surviving original paving should be retained and augmented.

English Heritage supports the protection of visually active frontages and introduction of new elements especially from the Royals Centre onto Pier Hill.

We are pleased to see the emphasis on protection of visually important views.

English Heritage supports the Landmark Buildings policy with the important caveats relating to protection of existing landmarks as included in the schedule in Appendix 4. We are pleased to see inclusion of the Pier in the schedule, although, presumably by oversight this has been omitted on the Proposals Map.

In discussing conservation areas, we are disappointed that there is no commitment to appraise these areas on a regular basis and to review some of the boundary anomalies, such as the east boundary of Cliff Town. This reiterates previous advice that English Heritage included in our letter of 5 August 2010, when in commenting on the Issues and Options consultation for the Central Area Action Plan we commented "that in order to fully understand and address change in this area more investigative work needs to be carried out. Our Conservation Principles, Policy and Guidance emphasises (para 62 onwards) the need to understand the fabric and evolution of a place and to identify who values the place and why they do so. Paragraph 89 underlines the value of specific investigation into understanding the impacts, or consequences, of proposed change".

Nonetheless English Heritage welcomes your document's strong emphasis on the role of heritage in the distinctive character of the town centre. We are pleased to see that it has become a strong theme in specific policies especially those relating to High Street and Central Sea Front where the value of heritage-led regeneration has not always been acknowledged in the recent past. We would support all the policies and add only these additional comments.

Clifftown. We support these proposals but recommend a stronger heritage strategy to include assessment of buildings for local listing and extension of the conservation area designation.

Frontages of Townscape Merit. We commend this concept, especially in streets outside the conservation areas, notably High Street. This responds to our previous concerns on undesignated assets such as the former Keddies Store. We welcome the emphasis on shop fronts but would add that we consider it essential to acknowledge the importance of roofscape as part of the overall building frontage.

While we welcome the consideration given to archaeology we consider following minor amendments would be appropriate:

For clarity, none of the above comments should be taken as formal objections to the soundness of the Area Action Plan. We would, however, hope that you may be able to give the recommended changes, highlighted above, your consideration as minor amendments to the plan.

As a general point, we are pleased to see that heritage has been integrated into the plan throughout the various chapters. We do not have any over-riding concerns in relation to the plan that would raise questions of soundness. Notwithstanding this, we would like to make some suggestions for minor amendments, for your consideration. These are outlined below together with other general comments which we hope you will find useful.

Open Space and the environment. We welcome the discussion of green and civic spaces and their identification in the preceding 6.3.1. A number of these spaces are within conservation areas, however another important feature are the street trees, which survive especially in Cliff Town.

We support the principles of the Public Realm Enhancements, especially the reduction of clutter. The sea front is an area that would benefit greatly, but its function as a busy traffic route requires imaginative thinking if the pedestrian is to be able to reclaim priority. Historic precedents could inform the materials and street furniture where evidence survives (as an example, the finial street name signs that were once a feature of the town). Areas of surviving original paving should be retained and augmented.

English Heritage supports the protection of visually active frontages and introduction of new elements especially from the Royals Centre onto Pier Hill.

We are pleased to see the emphasis on protection of visually important views.

English Heritage supports the Landmark Buildings policy with the important caveats relating to protection of existing landmarks as included in the schedule in Appendix 4. We are pleased to see inclusion of the Pier in the schedule, although, presumably by oversight this has been omitted on the Proposals Map.

In discussing conservation areas, we are disappointed that there is no commitment to appraise these areas on a regular basis and to review some of the boundary anomalies, such as the east boundary of Cliff Town. This reiterates previous advice that English Heritage included in our letter of 5 August 2010, when in commenting on the Issues and Options consultation for the Central Area Action Plan we commented "that in order to fully understand and address change in this area more investigative work needs to be carried out. Our Conservation Principles, Policy and Guidance emphasises (para 62 onwards) the need to understand the fabric and evolution of a place and to identify who values the place and why they do so. Paragraph 89 underlines the value of specific investigation into understanding the impacts, or consequences, of proposed change".

Nonetheless English Heritage welcomes your document's strong emphasis on the role of heritage in the distinctive character of the town centre. We are pleased to see that it has become a strong theme in specific policies especially those relating to High Street and Central Sea Front where the value of heritage-led regeneration has not always been acknowledged in the recent past. We would support all the policies and add only these additional comments.

Clifftown. We support these proposals but recommend a stronger heritage strategy to include assessment of buildings for local listing and extension of the conservation area designation.

Frontages of Townscape Merit. We commend this concept, especially in streets outside the conservation areas, notably High Street. This responds to our previous concerns on undesignated assets such as the former Keddies Store. We welcome the emphasis on shop fronts but would add that we consider it essential to acknowledge the importance of roofscape as part of the overall building frontage.

While we welcome the consideration given to archaeology we consider following minor amendments would be appropriate:

For clarity, none of the above comments should be taken as formal objections to the soundness of the Area Action Plan. We would, however, hope that you may be able to give the recommended changes, highlighted above, your consideration as minor amendments to the plan.

As a general point, we are pleased to see that heritage has been integrated into the plan throughout the various chapters. We do not have any over-riding concerns in relation to the plan that would raise questions of soundness. Notwithstanding this, we would like to make some suggestions for minor amendments, for your consideration. These are outlined below together with other general comments which we hope you will find useful.

Open Space and the environment. We welcome the discussion of green and civic spaces and their identification in the preceding 6.3.1. A number of these spaces are within conservation areas, however another important feature are the street trees, which survive especially in Cliff Town.

We support the principles of the Public Realm Enhancements, especially the reduction of clutter. The sea front is an area that would benefit greatly, but its function as a busy traffic route requires imaginative thinking if the pedestrian is to be able to reclaim priority. Historic precedents could inform the materials and street furniture where evidence survives (as an example, the finial street name signs that were once a feature of the town). Areas of surviving original paving should be retained and augmented.

English Heritage supports the protection of visually active frontages and introduction of new elements especially from the Royals Centre onto Pier Hill.

We are pleased to see the emphasis on protection of visually important views.

English Heritage supports the Landmark Buildings policy with the important caveats relating to protection of existing landmarks as included in the schedule in Appendix 4. We are pleased to see inclusion of the Pier in the schedule, although, presumably by oversight this has been omitted on the Proposals Map.

In discussing conservation areas, we are disappointed that there is no commitment to appraise these areas on a regular basis and to review some of the boundary anomalies, such as the east boundary of Cliff Town. This reiterates previous advice that English Heritage included in our letter of 5 August 2010, when in commenting on the Issues and Options consultation for the Central Area Action Plan we commented "that in order to fully understand and address change in this area more investigative work needs to be carried out. Our Conservation Principles, Policy and Guidance emphasises (para 62 onwards) the need to understand the fabric and evolution of a place and to identify who values the place and why they do so. Paragraph 89 underlines the value of specific investigation into understanding the impacts, or consequences, of proposed change".

Nonetheless English Heritage welcomes your document's strong emphasis on the role of heritage in the distinctive character of the town centre. We are pleased to see that it has become a strong theme in specific policies especially those relating to High Street and Central Sea Front where the value of heritage-led regeneration has not always been acknowledged in the recent past. We would support all the policies and add only these additional comments.

Clifftown. We support these proposals but recommend a stronger heritage strategy to include assessment of buildings for local listing and extension of the conservation area designation.

Frontages of Townscape Merit. We commend this concept, especially in streets outside the conservation areas, notably High Street. This responds to our previous concerns on undesignated assets such as the former Keddies Store. We welcome the emphasis on shop fronts but would add that we consider it essential to acknowledge the importance of roofscape as part of the overall building frontage.

While we welcome the consideration given to archaeology we consider following minor amendments would be appropriate:

For clarity, none of the above comments should be taken as formal objections to the soundness of the Area Action Plan. We would, however, hope that you may be able to give the recommended changes, highlighted above, your consideration as minor amendments to the plan.

As a general point, we are pleased to see that heritage has been integrated into the plan throughout the various chapters. We do not have any over-riding concerns in relation to the plan that would raise questions of soundness. Notwithstanding this, we would like to make some suggestions for minor amendments, for your consideration. These are outlined below together with other general comments which we hope you will find useful.

Open Space and the environment. We welcome the discussion of green and civic spaces and their identification in the preceding 6.3.1. A number of these spaces are within conservation areas, however another important feature are the street trees, which survive especially in Cliff Town.

We support the principles of the Public Realm Enhancements, especially the reduction of clutter. The sea front is an area that would benefit greatly, but its function as a busy traffic route requires imaginative thinking if the pedestrian is to be able to reclaim priority. Historic precedents could inform the materials and street furniture where evidence survives (as an example, the finial street name signs that were once a feature of the town). Areas of surviving original paving should be retained and augmented.

English Heritage supports the protection of visually active frontages and introduction of new elements especially from the Royals Centre onto Pier Hill.

We are pleased to see the emphasis on protection of visually important views.

English Heritage supports the Landmark Buildings policy with the important caveats relating to protection of existing landmarks as included in the schedule in Appendix 4. We are pleased to see inclusion of the Pier in the schedule, although, presumably by oversight this has been omitted on the Proposals Map.

In discussing conservation areas, we are disappointed that there is no commitment to appraise these areas on a regular basis and to review some of the boundary anomalies, such as the east boundary of Cliff Town. This reiterates previous advice that English Heritage included in our letter of 5 August 2010, when in commenting on the Issues and Options consultation for the Central Area Action Plan we commented "that in order to fully understand and address change in this area more investigative work needs to be carried out. Our Conservation Principles, Policy and Guidance emphasises (para 62 onwards) the need to understand the fabric and evolution of a place and to identify who values the place and why they do so. Paragraph 89 underlines the value of specific investigation into understanding the impacts, or consequences, of proposed change".

Nonetheless English Heritage welcomes your document's strong emphasis on the role of heritage in the distinctive character of the town centre. We are pleased to see that it has become a strong theme in specific policies especially those relating to High Street and Central Sea Front where the value of heritage-led regeneration has not always been acknowledged in the recent past. We would support all the policies and add only these additional comments.

Clifftown. We support these proposals but recommend a stronger heritage strategy to include assessment of buildings for local listing and extension of the conservation area designation.

Frontages of Townscape Merit. We commend this concept, especially in streets outside the conservation areas, notably High Street. This responds to our previous concerns on undesignated assets such as the former Keddies Store. We welcome the emphasis on shop fronts but would add that we consider it essential to acknowledge the importance of roofscape as part of the overall building frontage.

While we welcome the consideration given to archaeology we consider following minor amendments would be appropriate:

For clarity, none of the above comments should be taken as formal objections to the soundness of the Area Action Plan. We would, however, hope that you may be able to give the recommended changes, highlighted above, your consideration as minor amendments to the plan.