The joint IHBC-RTPI response is probably at the more negative end of the spectrum of submissions to CLG’s Planning policy Statement (PPS) 15 on Planning and the Historic Environment, at least of those seen by the IHBC among the 300 or so submissions. Significantly, a number number of heritage and other user organisations that had initially registered support for the PPS’s generalities have substantially re-assessed their positions in light of more detailed scrutiny and feedback from practitioners.
The Historic Towns Forum, representing a wide range of senior planning practitioners in local authorities with historic urban centres, ‘initially welcomed the publication of Draft PPS15 for consultation’. However, ‘having now studied its content in more detail, it is extremely concerned and disappointed at certain of its messages and believes that it is fundamentally compromised by the failure to enact the Heritage Protection Bill’. Consequently, ‘HTF feels that the consultation has been rushed, and regrets how much cannot be responded to meaningfully when so many supporting documents referred to in the PPS Practice Guide are not yet available for public comment. (TF is) concerned that the PPS will be adopted with inadequate scrutiny.’
Heritage Link, the historic environment link body, reflects similar concerns from the opposite end of the users’ spectrum, mainly for the 3rd sector. It has ‘expressed the consensus view of members that the PPS and guidance currently fall short of meeting their stated aims and, crucially, represent a potential weakening of protection for the historic environment. Key areas for concern outlined in the (Heritage link) response include:
•The implementation of terminology and policies based on Bills not yet enacted (Draft Heritage Protection Bill and Local Democracy, Economic Development and Construction Bill respectively);
•Narrowing of scope for public inclusion and engagement in the decision-making process in contrast to key principle set out in the Heritage White Paper;
•Lack of recognition of the historic environment’s contribution to economic, social and environmental benefits;
•Concern at the way climate change mitigation is positioned in relation to the historic environment;
•Possible underestimation of the burden on local authority resources, in relation to HERs and pre-application consultation;
•Absence of any assessment of the demands made on non-government heritage bodies either national or local – Annex A forecasts increased demand for their expertise;
•Omission of any reference to the role of local designation in place-making;
•Lack of sufficient clarity and practical help in the draft Practice Guide.’
The National Trust is ‘concerned in particular that, in moving from the current PPGs to the new PPS, there could be a loss in clarity of language and definition, which could create more scope for uncertainty – and potentially much legal wrangling in appeals (and ultimately in the courts)’. Other elements causing concern include ‘the assumption within the document that the historic environment acts as a barrier to development and climate change mitigation; the underestimate made of the burdens on local authorities; and the lack of required clarity and direction within the accompanying guidance’. The National Trust concludes that ‘unless these concerns are tackled we will not be able to support the PPS as currently drafted.
In contrast the Archaeology Forum, representing a range of bodies with archaeological interests, including Council for British Archaeology (CBA) and Institute for Archaeologists (IfA), as well as the National Trust, though not IHBC, considers that the draft’s weaknesses ‘may readily be addressed and should not delay the publication of the PPS as planned’. Its key proviso for the best outcome is that ‘English Heritage undertakes (the re-write) in conjunction with key sector bodies and practitioners’.
The IfA, with a membership of 2,800 archaeologists, addressed some more detailed issues, welcoming a number of improvements from the existing PPG 16 on Archaeology, but criticising the lack of coherence, lack of support for appropriate expertise, over-reliance on historic environment records for information, and the lack of an explicit assumption in favour of conservation’.
CBA, has ‘serious reservations about the drafting’ but despite these considers that ‘it is important to maintain momentum’ and ‘hopes (its) fears will prove to be unfounded’, as failure to progress would ‘signal that this area is no longer a Government priority with inevitable consequences for the resourcing of local authority historic environment and conservation services, which are already under great pressure’.
Of those supporting speedy progress, none have as yet reacted to the possibility of Tory commitment to a new Bill supporting wider reform.
Link to HTF response to CLG PPS15 consultation
Link to IfA response to CLG PPS15 consultation
Link to CBA response to CLG PPS15 consultation
Link to Heritage Link response to CLG PPS15 consultation
