The joint IHBC-RTPI response is probably at the more negative end of the spectrum of submissions to CLG\u2019s 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\u2019s generalities have substantially re-assessed their positions in light of more detailed scrutiny and feedback from practitioners.
\nThe Historic Towns Forum, representing a wide range of senior planning practitioners in local authorities with historic urban centres, \u2018initially welcomed the publication of Draft PPS15 for consultation\u2019. However, \u2018having 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\u2019. Consequently, \u2018HTF 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.\u2019<\/p>\n
Heritage Link, the historic environment link body, reflects similar concerns from the opposite end of the users\u2019 spectrum, mainly for the 3rd sector. It has \u2018expressed 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:<\/p>\n
\u2022The implementation of terminology and policies based on Bills not yet enacted (Draft Heritage Protection Bill and Local Democracy, Economic Development and Construction Bill respectively);<\/p>\n
\u2022Narrowing of scope for public inclusion and engagement in the decision-making process in contrast to key principle set out in the Heritage White Paper;<\/p>\n
\u2022Lack of recognition of the historic environment\u2019s contribution to economic, social and environmental benefits;<\/p>\n
\u2022Concern at the way climate change mitigation is positioned in relation to the historic environment;<\/p>\n
\u2022Possible underestimation of the burden on local authority resources, in relation to HERs and pre-application consultation;<\/p>\n
\u2022Absence of any assessment of the demands made on non-government heritage bodies either national or local \u2013 Annex A forecasts increased demand for their expertise;<\/p>\n
\u2022Omission of any reference to the role of local designation in place-making;<\/p>\n
\u2022Lack of sufficient clarity and practical help in the draft Practice Guide.’<\/p>\n
The National Trust is \u2018concerned 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 \u2013 \u00a0and potentially much legal wrangling in appeals (and ultimately in the courts)\u2019. Other elements causing concern include \u2018the 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\u2019. The National Trust concludes that \u2018unless these concerns are tackled we will not be able to support the PPS as currently drafted.<\/p>\n
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\u2019s weaknesses \u2018may readily be addressed and should not delay the publication of the PPS as planned\u2019. Its key proviso for the best outcome is that \u2018English Heritage undertakes (the re-write) in conjunction with key sector bodies and practitioners’.<\/p>\n
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’.<\/p>\n
CBA, has \u2018serious reservations about the drafting\u2019 but despite these considers that \u2018it is important to maintain momentum\u2019 and \u2018hopes (its) fears will prove to be unfounded’, as failure to progress would \u2018signal 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’.<\/p>\n
Of those supporting speedy progress, none have as yet reacted to the possibility of Tory commitment to a new Bill supporting wider reform.<\/p>\n
Link to HTF response to CLG PPS15 consultation<\/a> The joint IHBC-RTPI response is probably at the more negative end of the spectrum of submissions to CLG\u2019s Planning policy Statement (PPS) 15 on Planning and the Historic Environment, at least of those seen by the IHBC among the 300 … Continue reading
\nLink to IfA response to CLG PPS15 consultation<\/a> <\/a>
\nLink to CBA response to CLG PPS15 consultation<\/a>
\nLink to Heritage Link response to CLG PPS15 consultation<\/a><\/p>\n","protected":false},"excerpt":{"rendered":"