The Heritage Alliance welcomes PPS5
Heritage Alliance welcomes the publication of Planning Policy Statement 5 (PPS5) for the Historic Environment this week (23 March 2010), as representing a significant milestone in the drive towards a heritage protection system fit for the 21st century.
The streamlined PPS5 replaces existing planning guidance in PPGs15 and 16 and introduces a number of new concepts aimed at encouraging better understanding and management of the historic environment, in order to capitalise on the social and economic benefits of well considered conservation and regeneration. The Heritage Alliance and its members have worked closely with Communities and Local Government (CLG), Department for Culture, Media and Sport (DCMS) and English Heritage throughout the consultation period to ensure that new concepts are robust enough to enable positive change whilst upholding current levels of heritage protection.
“Heritage is proven to be instrumental in delivering economic prosperity and community cohesion through quality place-making. As such it deserves to be a key consideration in modern planning policy”, said Dr Mike Heyworth, Chair of The Heritage Alliance Spatial Planning Advocacy Group.
“PPS5 represents a significant step forward in the Government’s recognition of the true value of our nation’s heritage. Together with the Government Vision statement there is now clear direction on how to leverage and safeguard this vital resource for future generations”.
For the first time PPS5 and the Practice Guide take an integrated approach to all types of heritage asset such as buildings, archaeological remains, monuments, landscapes, parks & gardens and even historic battlefields. It is the significance of an asset that policy now sets out to promote and protect, and steps for determining and recording significance are outlined in the Practice Guide. For Local Authorities it means greater clarity on the acceptability of development relating to the historic environment, whilst for Alliance members, involved in the conservation of all areas of the historic environment, promotion of expert advice offers the opportunity for greater engagement in the pre-application process.
Nevertheless, although PPS5 represents a positive move forward in the effective management of the historic environment, concerns remain over resource implications for local authorities. The PPS comes at a time when there is substantial evidence of the depletion of local authority conservation and planning expertise. In an attempt to overcome this challenge The Heritage Alliance is working with English Heritage on developing a comprehensive training and guidance programme on PPS5 for a range of stakeholders.
Mike Heyworth comments: “There is a risk that the burden on local authority resources has been underestimated. Training and guidance should mitigate this, but a timely review following the implementation of PPS5 and Guidance would guard against any drop in heritage protection levels. This should be the next step for any new Government, closely followed by a Heritage Protection Act to underpin new planning policy”.
A draft Heritage Protection Bill underwent pre-legislative scrutiny in summer 2008 but was dropped from subsequent parliamentary programmes despite strong all-party backing. The Bill, widely supported by the sector, contained a broad range of reforms that would add further clarity, efficiency and certainty to the way in which the historic environment is used, managed and protected. Although some reforms have been taken forward without the Bill, key provisions have been lost – leaving gaps in protection. These include:
- a single unified designation system
- the statutory duty for Local Planning Authorities to maintain or have access to Historic Environment Records
- interim protection for heritage assets under consideration for listing
- statutory obligations on Heritage Protection Agreements
- reversal of the ‘Shimizu judgment’ and other proposals to strengthen Conservation Area protection
- the revision of Class Consents to avoid ongoing damage to archaeological remains from agricultural activity
- UK ratification of the 1954 Hague Convention for the Protection of Cultural Property in the Event of Armed Conflict and accompanying protocols; the UK being the only major economy not to do so.
Sector responses to the publication of the PPS:
- English Heritage
- Institute for Archaeologists
- Institute of Historic Building Conservation
- Country Land and Business Association
- RESCUE – The British Archaeological Trust
Heritage Link has submitted a response to the consultation on the draft PPS 15: Planning for the Historic Environment and the draft Practice Guide. The response was informed by member’s feedback gathered during a dedicated PPS15 members’ seminar and through communication on an individual basis.
It supports the overarching objectives of PPS15 to develop planning policy for the historic environment that is clear, up-to-date and which takes an integrated approach to all types of heritage asset. Policies that encourage greater understanding of heritage assets, promotion of pre-application consultation and referral to expert advice are welcomed.
However, Heritage Link has expressed the consensus view of members that the PPS and guidance currently fall short of meeting their stated aims and represent a potential weakening of protection for the historic environment. Key areas for concern outlined in the response include:
- 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 principles set
- out in the Heritage White Paper;
- Complete 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, interpretation of new terminology
- and guidance 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.
Heritage Link took the opportunity to urge the Government and English Heritage to implement practical suggestions for amendment put forward in our response and those of individual members. Meanwhile, a proposal was put forward to engage a working group of members in re-drafting the Practice Guide so that both the PPS and guidance might be published concurrently before the next general election.
The Heritage Link response, those of member organisations and others are available to download below:
- The National Trust response
- Society for the Protection of Ancient Buildings (SPAB) response
- Council for British Archaeology response
- Historic Houses Association response
- Historic Towns Forum response
- IHBC and RTPI joint response
http://www.ihbc.org.uk/ and http://www.rtpi.org.uk
- Joint Committee of the National Amenity Societies response
- Institute for Archaeologists