image for illustration: Chris CC BY-SA 2.0 vis Wikimedia Commons
A recent IHBC online discussion covered the wide-ranging implications for conservation in England’s new National Planning Policy Framework (NPPF), complement a raised profile as IHBC Chair, David McDonald OBE, fronts some early thoughts picked up by Planning Resource.
IHBC Chair David McDonald said: ‘It is essential for the IHBC to engage with all parts of policy development that shape conservation, with the NPPF as an obvious focus for England just now.’
‘But we should not just to talk among ourselves. We need a wider impact too.’
‘That’s why we’re especially delighted to see the impact of internal discussions – such as the practitioner-led online exploration of the NPPF outlined below – informing an early take form us highlighted in a recent Planning Resource feature.’
‘Threads from both are captured below, but the key message here for the IHBC, and for me, is the need to move our messages outside the IHBC as well as inside it!’.
The IHBC summarises its early open online discussion as follows:
The latest planning reforms mark a significant shift in the way development and heritage will be considered, bringing both welcome improvements and important grounds for concern. While greater clarity and a number of positive changes have been introduced, questions remained about the balance between national direction, local decision-making and the protection of the historic environment.
The reforms were closely scrutinised and IHBC Policy Secretary, Roy Lewis led the session attended by over a hundred people. Several changes could provide greater clarity and consistency, but others may have unintended consequences for how harm to heritage assets is assessed and how change is managed.
Some key opportunities and concerns noted as arising from the new framework:
The new planning framework contains a number of welcome changes, particularly the clearer distinction between plan-making and decision-taking. The removal of the controversial term ‘less than substantial harm’ is also a positive step, alongside the explicit recognition that Local Plans should add value rather than simply repeat national policy.
However, significant concerns remained. The centralisation of control over the planning system, together with ‘default yes to development’ policies, risks reducing the scope for locally informed decision-making and democratic control.
New categories of heritage harm
The introduction of new categories of harm — harm, substantial harm and total loss — could result in more proposals being assessed as causing substantial harm. But the dividing line between harm and substantial harm is likely to remain contested, with interpretation and judgement continuing to play an important role.
The revised definition of ‘conservation’ also raises questions. The unexpected addition of the word ‘preserve’ could have significant implications, and it remains to be seen whether it will lead to greater resistance to change affecting heritage assets.
New requirements for heritage assessments
There was less concern than expected about the new requirement for applicants to assess the impact of proposals on heritage assets. Importantly, the policy makes clear that decision-makers must ensure that these assessments properly and accurately reflect the effects of proposed development.
The removal of ‘optimum viable use’ was viewed with some concern, although its practical application has often proved difficult to define and apply consistently in practice. The new requirement to ‘maintain or secure a use consistent with conservation’ may present similar challenges and will require careful interpretation.
Local lists can be helpful but Article 4 concerns noted
Local heritage lists were broadly welcomed as a valuable means of identifying and recognising non-designated heritage assets even where not accompanied by Article 4 Directions.
Concerns remerged about possible restrictions on the use of Article 4 Directions as the policy does not specifically identify heritage conservation among the circumstances in which Article 4 Directions may be used. This could leave an important gap in the protection of locally valued heritage.
A significant shift for planning and heritage
Overall, the changes represent a significant evolution of the planning framework. While several reforms have been welcomed, important questions remain about how the new policies will operate in practice and their implications for the protection and conservation of the historic environment.
David Blackman, consultant for IHBC’s Parliamentare engagement, writes in Planning Resource: Under revamped national policy, development proposals will now be subject to a four-tier system for assessing their impact on designated heritage assets. Practitioners believe the revised wording provides greater clarity and note the new support for schemes that would positively impact the historic environment….
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… David McDonald [OBE]… of professional practitioners’ body the Institute of Historic Building Conservation, welcomed the removal of the ‘less than substantial harm’ aspect of the NPPF’s heritage test as ‘definitely a good thing’.
See more on the IHBC’s NPPF discussion at: IHBC talks NPPF… on Tuesday 1 Sept, from 4PM: Join in the online discussion of the new Policy Framework and its implications
See David Blackman on ‘What the new NPPF’s simplified heritage impact test means for planners and developers’ Planning Resource (090926): read more here.
