{"id":48081,"date":"2026-09-18T14:34:50","date_gmt":"2026-09-18T13:34:50","guid":{"rendered":"https:\/\/newsblogs.ihbc.org.uk\/?p=48081"},"modified":"2026-09-18T14:34:50","modified_gmt":"2026-09-18T13:34:50","slug":"ihbcs-first-thoughts-from-the-new-nppf-on-what-the-nppf-means-for-conservation-in-england-and-what-remains-unanswered-with-an-early-push-on-planning-resource","status":"publish","type":"post","link":"https:\/\/newsblogs.ihbc.org.uk\/?p=48081","title":{"rendered":"IHBC\u2019s first thoughts from the new NPPF: On \u2018\u2026what the NPPF means for Conservation in England and what remains unanswered\u2019, with an early push on Planning Resource"},"content":{"rendered":"\n
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image for illustration: Chris CC BY-SA 2.0 vis Wikimedia Commons<\/a><\/em><\/p>\n\n\n\n

A recent IHBC online discussion covered the wide-ranging implications for conservation in England\u2019s 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<\/em>.<\/p>\n\n\n\n\n\n\n\n

IHBC Chair David McDonald said: \u2018It 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.\u2019<\/p>\n\n\n\n

\u2018But we should not just to talk among ourselves.  We need a wider impact too.\u2019<\/p>\n\n\n\n

\u2018That\u2019s why we\u2019re especially delighted to see the impact of internal discussions \u2013 such as the practitioner-led online exploration of the NPPF outlined below \u2013 informing an early take form us highlighted in a recent Planning Resource<\/em> feature.\u2019<\/p>\n\n\n\n

\u2018Threads 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!\u2019.<\/p>\n\n\n\n

The IHBC summarises its early open online discussion as follows:<\/p>\n\n\n\n

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.<\/p>\n\n\n\n

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.<\/p>\n\n\n\n

Some key opportunities and concerns noted as arising from the new framework:<\/p>\n\n\n\n

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 \u2018less than substantial harm\u2019 is also a positive step, alongside the explicit recognition that Local Plans should add value rather than simply repeat national policy.<\/p>\n\n\n\n

However, significant concerns remained. The centralisation of control over the planning system, together with \u2018default yes to development\u2019 policies, risks reducing the scope for locally informed decision-making and democratic control.<\/p>\n\n\n\n

New categories of heritage harm<\/p>\n\n\n\n

The introduction of new categories of harm \u2014 harm, substantial harm and total loss \u2014 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.<\/p>\n\n\n\n

The revised definition of \u2018conservation\u2019 also raises questions. The unexpected addition of the word \u2018preserve\u2019 could have significant implications, and it remains to be seen whether it will lead to greater resistance to change affecting heritage assets.<\/p>\n\n\n\n

New requirements for heritage assessments<\/p>\n\n\n\n

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.<\/p>\n\n\n\n

The removal of \u2018optimum viable use\u2019 was viewed with some concern, although its practical application has often proved difficult to define and apply consistently in practice. The new requirement to \u2018maintain or secure a use consistent with conservation\u2019 may present similar challenges and will require careful interpretation.<\/p>\n\n\n\n

Local lists can be helpful but Article 4 concerns noted<\/p>\n\n\n\n

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.<\/p>\n\n\n\n

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.<\/p>\n\n\n\n

A significant shift for planning and heritage<\/p>\n\n\n\n

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.<\/p>\n\n\n\n

David Blackman, consultant for IHBC\u2019s Parliamentare engagement, writes in Planning Resource<\/u><\/em>: 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\u2026.<\/p>\n\n\n\n

\u2026.<\/p>\n\n\n\n

\u2026 David McDonald [OBE]\u2026 of professional practitioners\u2019 body the Institute of Historic Building Conservation, welcomed the removal of the \u2018less than substantial harm\u2019 aspect of the NPPF\u2019s heritage test as \u2018definitely a good thing\u2019.<\/p>\n\n\n\n

See more on the IHBC’s NPPF discussion at: IHBC talks NPPF\u2026 on Tuesday 1 Sept, from 4PM: Join in the online discussion of the new Policy Framework and its implications<\/a><\/p>\n\n\n\n

See David Blackman on \u2018What the new NPPF\u2019s simplified heritage impact test means for planners and developers\u2019 Planning Resource (090926): read more here<\/a>.<\/p>\n\n\n\n

Read the new NPPF here<\/a><\/p>\n","protected":false},"excerpt":{"rendered":"

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\u2019s new National Planning Policy Framework (NPPF), complement a raised profile as IHBC Chair, David McDonald OBE, fronts … Continue reading →<\/span><\/a><\/p>\n","protected":false},"author":6,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[1],"tags":[916,450,703,16],"class_list":["post-48081","post","type-post","status-publish","format-standard","hentry","category-ihbc-newsblog","tag-government-uk","tag-ihbc","tag-nppf","tag-planning"],"_links":{"self":[{"href":"https:\/\/newsblogs.ihbc.org.uk\/index.php?rest_route=\/wp\/v2\/posts\/48081","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/newsblogs.ihbc.org.uk\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/newsblogs.ihbc.org.uk\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/newsblogs.ihbc.org.uk\/index.php?rest_route=\/wp\/v2\/users\/6"}],"replies":[{"embeddable":true,"href":"https:\/\/newsblogs.ihbc.org.uk\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=48081"}],"version-history":[{"count":1,"href":"https:\/\/newsblogs.ihbc.org.uk\/index.php?rest_route=\/wp\/v2\/posts\/48081\/revisions"}],"predecessor-version":[{"id":48082,"href":"https:\/\/newsblogs.ihbc.org.uk\/index.php?rest_route=\/wp\/v2\/posts\/48081\/revisions\/48082"}],"wp:attachment":[{"href":"https:\/\/newsblogs.ihbc.org.uk\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=48081"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/newsblogs.ihbc.org.uk\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=48081"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/newsblogs.ihbc.org.uk\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=48081"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}