Alliance Chairman Loyd Grossman’s letter to The Times appears today (1 June), congratulating the Chancellor on coming to the aid of our edible heritage (by reversing the ‘pasty tax’) but highlighting the fact that the future of our world class built heritage is still in jeopardy. The proposed’ heritage tax’, which will levy 20 per cent on the cost of alterations to Listed Buildings, will damage our economic prosperity as well as the national assets that provide us all with inspiration and pleasure.
Referring to the scant evidence produced by HMRC, he calls for the zero rating to be retained for all building types and for all owners.
See our latest briefing to MPs here.
I am delighted that the Chancellor has come to the aid of our edible heritage by reconsidering his decision to impose VAT on the Cornish pasty. Perhaps he would now also consider similar measures to secure the future of our built heritage?
The ‘pasty tax’ was an attempt to tidy up the VAT regime and, in principle, the removal of such anomalies is to be welcomed, but taxation policies must deliver long term, net benefits to the public rather than just convenience to the Treasury. The withdrawal of an extremely rare EU concession allowing a zero rate of VAT on approved alterations to listed buildings will, I believe, damage this country’s economic prospects as well as our quality of life.
Our heritage is the vital national asset upon which our fast growing, money earning tourism industry is based. Beyond the tourism industry, the three per cent of buildings in this country that are listed are, by definition, a public good which provide all of us with inspiration, pleasure and the context in which enterprise and creativity can flourish.
Owners of listed buildings take on responsibilities on behalf of the nation. All over the country, community groups, private individuals and small charities now face the prospect of a further 20% being added to their costs.
Our Freedom of Information request revealed that a sample of just over 100 cases (out of 29,000 listed building consent decisions in 2010-11) was used to imply that the zero rating is unnecessary for heritage purposes. Nor can HMRC substantiate the claim that this ‘loophole’ is being used to get tax relief on swimming pools and other lifestyle improvements for the super rich.
The Chancellor has already wisely conceded that this proposal would inflict huge damage on historic places of worship. It is clearly in the long term interest of the country to retain the zero rating for all building types and for all owners.
Chairman, The HeritageAlliance
The next few weeks are critical in persuading Government to stop the budget proposal to withdraw the zero VAT rate on approved alterations to listed buildings.
The Alliance has used the many emails and letters it has received to identify MPs already alerted and concerned about the damage this measure will inflict on the finest of our historic environment. The Alliance’s latest briefing takes account of the HMRC reply to its Freedom of Information request, and the latest concessions over other VAT ‘anomalies’.
HMRC’s reply to the Alliance’s Freedom of Information request showed what a minute sample the ‘evidence’ was based on and that there is no substance to the allegation that abuse involves wealthy owners building swimming pools with this tax relief.
Like the ‘pasty’ and ‘caravan’ taxes, the measure is an attempt to tidy up the VAT regime but unlike these taxes, the government has ignored the public good. Our listed buildings are designated as national assets and they should not be the victims of an HMRC drive for tidiness in their own internal operations.
Make sure you write to your MP to explain what damage an extra 20% VAT will have on the viability of our listed buildings!
13 April 2012: Joint letter to the Times from Loyd Grossman, Alliance Chairman
In conjunction with the National Trust, Civic Voice, RSPB, the Wildlife Trusts and CPRE, the Alliance called on Government to continue the good work done in the NPPF. See the full text here.
27 March 2012: The Alliance response to reformed NPPF
On 27 March 2012 the then-Planning Minister Greg Clark published the updated NPPF document. See our response here.
21 December 2011: The Alliance response to the CLG Select Committee’s report
On 21 December the Alliance responded to the CLG Select Committee’s report on the NPPF. See our response here.
25 October 2011: The Alliance briefs Peers ahead of NPPF Grand Committee debate
On 25 October the Alliance delivered to Peers its briefing on the NPPF, ahead of the Lords’ Grand Committee debate on Thursday 27 October at 2pm. See our briefing here.
14 October 2011: The Alliance submits it response to the CLG consultation
Following consultation with members, on Friday 14 October The Heritage Alliance submitted its response to the Department for Communities and Local Government’s NPPF consultation. See our covering letter here and our full response here.
Round-up of Alliance members’ comments & responses on the NPPF consultation
- NPPF must not be silent on culture, says The Theatres Trust
- We believe in growth but not at all costs, says The National Trust
- We have strong concerns the NPPF would be both unworkable and damaging, says CPRE
- We need more planning not less if we’re to achieve smart growth not urban sprawl, says Civic Voice
- The NPPF proposes a more flexible system within environmental limits, says the CLA
- The NPPF lacks key detail and clarity on the historic environment, says the HHA
- The NPPF represents dumbing down and oversimplfication of complex issues, says Greenspace
- Concerns remain about degree of protection for undesignated assets and lack of emphasis on the need for specialist expertise, says FAME
- The NPPF falls into the trap of equating brevity with clarity, says the Historic Towns Forum
- The NPPF could lead to sites and buildings of archaeological interest being destroyed without adequate investigation, analysis and dissemination, says the IfA
- There are concerns that the NPPF will leave local communities and planning authorities largely powerless in the face of developer pressure, says the Ramblers Association
- Significant further changes are needed to maintain protection at PPS5 levels, says the CBA
- NPPF not acceptable unless SD definition fully embraces environmental & cultural factors, and includes PPs5′s presumption in favour of conservation of designated assets, says SPAB
- ‘Yes’ to the presumption in favour of sustainable development, but ‘No’ to its ambiguous interpretation, says IHBC
Members whose responses haven’t yet been noted above can email their link for inclusion to Emma Robinson
26 September 2011: The Alliance hosts members’ forum on NPPF response
The Heritage Alliance’s members’ forum on the National Planning Policy Framework took place on Monday 26 September from 2.00pm to 5.00pm in the Court Room at St Andrew Holborn, 7 St Andrew Street, London EC4A 3AB. The afternoon give members an opportunity to feed-in directly to the Alliance’s formal response to the NPPF consultation, find out more about the Government’s proposals, and meet other members, Alliance Trustees and staff. The Alliance is currently formulating its response, which will be published here shortly.
16 September 2011: The Heritage Alliance submits its evidence to the Select Committee Inquiry
In July the House of Commons Communities and Local Government Committee and the House of Commons Environmental Audit Committee launched an Inquiry into the NPPF, calling for written submissions on the way the presumption in favour of sustainable development is dealt with in the document.
The two committees agreed that the evidence received by the CLG Committee would be shared with the EAC, and the EAC will seek to conclude its brief inquiry in time to inform the CLG Committee’s inquiry. The CLG Committee intends to hold oral evidence sessions in October and November. For the full list of questions the committee is seeking evidence on, and the guidelines for submission, click here.
The Alliance submitted its evidence to the Inquiry on 16 September. It’s now public here.
25 July 2011: The Heritage Alliance’s initial comments on the draft NPPF
We will comment more fully following comprehensive liaison with our members at our NPPF forum on 26 September.
The Alliance welcomes the publication of the long-awaited draft National Planning Policy Statement (NPPF), and supports the general principle behind the Government’s planning reforms – to empower local communities.
Whilst we support the intention to simplify planning policy and guidance, we strongly urge the Government not to lose sight of the need to retain strong and unambiguous policy and guidance for specific areas. We have concerns about several areas of the draft NPPF, which if left unresolved would result in a downgrading of protection for the historic environment. This cannot be allowed to happen. Our concerns are focussed on:
1. The presumption in favour of sustainable development: The Heritage Alliance believes strongly that the NPPF should indeed channel economic growth, but should not be led by it. We are concerned that the strong bias in favour of granting permission throughout the document would result in decisions being made without sufficient consideration being given to environmental, cultural and social considerations.
2. Are principles of PPS5 adequately incorporated into the NPPF?: Planning Policy Statement 5: Planning for the Historic Environment (PPS 5) embraces a holistic, integrated approach to the management of change in the historic environment. The widely accepted policy principles embedded in PPS5 should be carried through in to the final NPPF without any diminution of their standing, to provide a workable tool for practitioners, owners and applicants. It was hoped that there would be a more overt statement in favour of conservation than that which appears in the Historic Environment section of the current NPPF draft, and definitions such as ‘substantial harm’ will certainly need to be explored in more detail.
3. Planning documents must be fully integrated: The NPPF, Localism Bill and related Practice Guidance must be fully integrated and coherent as a whole, to ensure a clear framework in which our irreplaceable historic environment can continue to deliver a wide range of public goods and, not least, safeguard our truly wonderful heritage for future generations to enjoy.
27 June 2011: The Heritage Alliance’s response to the Practitioners Advisory Group draft
The Practitioners Advisory Group (PAG) - appointed by the Decentralisation Minister Greg Clark - held a meeting on 8 June, at which The Heritage Alliance was present, to discuss its draft of the new National Planning Policy Framework (NPPF). The PAG encouraged the historic environment sector to propose amendments to its draft, which would be forwarded to the Department for Communities and Local Government (DCLG). The Heritage Alliance’s response to the PAG - copied to Decentralisation Minister at DCLG Greg Clark, and Heritage Minister at DCMS John Penrose, can be found here.
The Localism Bill became an Act of Parliament on 15 November 2011.
Over the last few months we were busily briefing Parliamentarians on the Localism Bill. Details of all our briefings can be found below…
On 2 November the Alliance distributed to MPs its briefing for the Commons’ consideration of Lords Amendments, scheduled for 7 November.
On 10 and 12 October the Alliance’s amendments – which cover recognition of cultural wellbeing as a purpose for neighbourhood development orders, and the need for a balanced definition of sustainable development in the National Planning Policy Framework – were laid before the Lords.
The Alliance was also pleased to see a Government amendment proposed by Baroness Hanham (DCLG minister in the Lords) that modifies the designation of neighbourhood forums, proposing that forums which are established for the express purpose of promoting business must also include the purpose of improving the social and environmental wellbeing of an area – one of the issues which the Alliance has been campaigning on.
On 31 August the Alliance disseminated its House of Lords Report Stage briefing to Peers. We’re also meeting with Peers in person.
On 14 July The Heritage Alliance’s amendments relating to cultural wellbeing and the status of planning policy, tabled by Lord Brooke, were supported by Lord Stevenson and Lord Clement-Jones – thus gaining the support of the three main parties. Baroness Whittaker tabled an amendment put forward by Alliance member Civic Voice and the RTPI, to prevent neighbourhood planning forums being created solely to promote business needs.
On 30 June Lord Brooke of Sutton Mandeville tabled two Alliance amendments for consideration in Lords committee (148AZZA* and 152D*) - supporting the Alliance’s proposals for recognition of cultural wellbeing, the balance of public/private investment in neighbourhoods, and the status of national planning guidance in Neighbourhood Development Orders.
On 27 June the Alliance disseminated its House of Lords Committee Stage briefing to Peers. We’re also meeting with Peers in person.
On 31 May the Alliance disseminated its House of Lords Second Reading briefing to Peers, in advance of the second reading on 7 June. Keep up-to-date with the Bill’s progress here.
On 13 May the Alliance disseminated its Report Stage and Third Reading briefing to Parliamentarians. The Report Stage and Third Reading has been set for 17 – 18 May. Keep up-to-date with the Bill’s progress here.
On 1 March the Public Bill Committee reached Amendment 149 (to leave out paras 22 – 24 of Schedule 12 of the Localism Bill): the full debate can be viewed here (Columns 697 – 701). Minister for Decentralisation Greg Clark MP acknowledged that “as drafted, the Bill gives rise to understandable concerns on the part of the heritage community” and committed that “we will come back at a later stage with something that reflects the amendment’s intention”.
On 14 February the Alliance submitted its statement of support regarding Amendment 149 to the Public Bill Committee. Click here to view the statement and list of supporting bodies in full.
On 3 February The Heritage Alliance submitted its evidence to the Public Bill Committee regarding the Localism Bill. This memorandum has now been published on the Committee’s website, here and can be viewed below.
THE HERITAGE ALLIANCE EVIDENCE TO THE PUBLIC BILL COMMITTEE:
1. The Heritage Alliance is the largest coalition of non-government heritage interests in England. Together its members own, manage and care for the vast majority of England’s heritage.
2. Established in 2002 by the voluntary heritage groups themselves, the Alliance brings together 89 major organisations from specialist advisers, practitioners and managers, volunteers and owners, to national funding bodies and organisations leading regeneration and access projects. Their specialist knowledge and expertise across a huge range of issues – including planning matters and asset transfer – is a highly valuable national resource much of which is contributed on a voluntary basis for public benefit. They are supported in turn by thousands of local groups and around 5 million members, with a huge volunteer input of over 450,000 a year.
3. The Heritage Alliance welcomes the Coalition Government’s intention to shift the balance of policy-making more towards the communities who care about them. Our research in 2005 Making Consultation Matter revealed high levels of participation in local planning but widespread frustration too.
4. The Localism Bill has a key role in protecting and enhancing our surroundings for the benefit of us all and for future generations to enjoy. Our main concern is to consider the implications of the Bill, as it currently stands, for the historic environment.
5. Our recommendations relate to three key areas:
- How the draft Bill upholds the principles of our planning system
- The degree to which the Localism Bill supports national heritage interests
- The capacity and expertise of local people to determine and implement Neighbourhood Development Plans and Orders.
How the draft Bill upholds the principles of our planning system
6. We would like to see the Bill clearly uphold the key principle of the UK’s current planning system: to reach a balance between competing, but not always equally articulate, interests to ensure that long-term public benefit is achieved. The Bill should also state that sustainable development, balancing the sometimes competing needs of the environment, the community and the economy, is the objective of all plan-making including Neighbourhood Development Plans.
7. The National Planning Policy Framework (NPPF) is one of the key reference points for the Localism Bill. The NPPF should make it clear that the protection of the historic environment is of strategic importance and upholds the policies established in the recently issued and concise policy document PPS5.
8. In drawing up Neighbourhood Development Plans (NDPs), it is not clear which policies in Local Development Frameworks are so ‘strategic’ that they should be taken into account. We suggest that historic environment policies in Local Development Frameworks are always of strategic importance and should already form part of the Local Authority’s Core Strategies. NDPs should be drawn up in conformity with overarching historic environment policies.
The degree to which the Localism Bill supports national heritage interests
9. We welcome the Coalition Government’s intention that there should be no lessening in the level of protection for national heritage assets.
10. We welcome the proposed list of ‘community’ assets. This might be related to ‘Local Lists’ of heritage assets which many Local Authorities use in addition to national designations, when considering planning applications. Our historic environment provides ‘roots’ and a sense of place, frequently offering an identity or the symbol of the settlement. The evidence of past can often provide a basis for the ‘future history’ of a community and in a fast changing world, heritage and history offer continuity and a ‘backdrop’ to the immediate. These have a function just as potent as a post office or community centre and frequently provide the ‘envelope’ for community services.
11. We welcome the amendments to the enforcement rules making it easier for Local Authorities to tackle abuses of the system.
12. We welcome the changes to the community infrastructure levy which mean the levy on new development can be used on ongoing infrastructure costs (including those related to the historic environment) as well as capital costs
13. We are however concerned that Sections 66 and 72 of the Town & Country Planning Act 1990 would be amended by Schedule 12 (paragraph 23) of the Localism Bill. This removes the general duty, when Neighbourhood Development Orders are being drawn up, to preserve listed buildings (66(1)) as well as the duty to preserve and enhance the character or appearance of Conservation Areas (72(1)). While Neighbourhood Development Orders should always take account of nationally protected heritage assets, this paragraph could see the removal of planning permission for development which affects a listed building or its setting. The vast majority of nationally important archaeology is currently protected by planning permission rather than by scheduling and again could lose the existing level of protection if this paragraph were implemented as currently phrased.
14. Matters relating to nationally important archaeology; the setting of listed buildings and scheduled monuments; extensions to a listed place of worship that falls under ecclesiastical exemption; development in conservation areas; the protection of registered parks and gardens; and the protection of buffer zones around World Heritage Sites are of national importance and should be taken into consideration in drawing up Neighbourhood Development Plans and Neighbourhood Development Orders.
The capacity and expertise of local people to determine and implement Neighbourhood Plans
15. We welcome the intention of the Bill to empower and support local communities to get involved to improve their local environment. People care deeply about the historic environment: Civic Voice’s recent poll rates the presumption in favour of conserving designated heritage assets as by far the top planning policy most people want to keep (62.6%).
16. The Bill may only provide the statutory framework, but we must raise some practical issues which could be dealt with in guidance.
17. While Local Planning Authorities can support Neighbourhood Forums to draw up the Neighbourhood Development Plans by providing advice and expertise, we query the capacity of Local Planning Authorities to supply this essential enabling support in view of widespread budget cuts. Nor can Local Authorities support the Plans financially. As these could cost between £5000 – £250,000, and the community bears the cost of the Strategic Environmental Assessment too, this means that such plans may be concentrated in more affluent areas. Funding via the Community Infrastructure Levy may be limited in underperforming areas. The opportunities could also be open to abuse where there is private sector interest in the new system because of the potential financial benefits for developers and landowners.
18. The Bill states that a Neighbourhood Forum must have a minimum of three people who live or want to live in the area. It is not clear how the Local Authority is to decide on which group of 3 people best represents the community. Further guidance is required to avoid damaging conflict here, even a breakdown of neighbourliness. Unless the planning process does secure wide community involvement there are some real dangers that small numbers of possibly-unrepresentative people will set the agenda or conversely that neighbourhood forums will be unduly influenced by developer interests.
19. Although local interests are important and we do not underestimate the quality of expertise available in many local communities, there is also significant knowledge and expert advice in our national civil society, outside central and local government. Many of the Alliance’s membership organisations, most notably the National Amenity Societies but also for example the Battlefields Trust and the Theatres Trust, are experts in their field. We recommend that these bodies should continue to be consulted on planning matters at the same level as at present.
20. There are millions of people who care deeply about historic environments, working or visiting them but without the residential qualifications for a parish council or neighbourhood forum. It is therefore vital the new concept of Neighbourhood Planning is placed firmly in line with the more strategic policies in LDFs and wider context of the National Planning Policy Framework, Planning Policy Statement 5 and other PPSs that have a key role in place shaping so that all can enjoy the social, educational, environmental and economic benefits of our heritage.
Contact: Kate Pugh, Chief Executive
020 7233 0800
The Alliance’s most recently established Advocacy Group on rural heritage has made the case for a more integrated approach to our landscapes, promoting the position taken by the European Landscape Convention that any division between their natural and historic qualities is artificial. The Group’s response to the Government consultation on the Natural Environment White Paper goes on to recognise the importance of the Environmental Stewardship scheme in conserving the natural and historic environments for public benefit, confirming that its successful operation in England is noted and respected by the European Commission.
In framing the priorities for the UK’s role in EU and international action, the Advocacy Group recommends a re-orientation of policy in the next phase of the Common Agricultural Policy to allow a more holistic approach to landscape protection and management, recognising that farmed cultural landscapes are an important public good and that in general public money should be used for public goods.
Following the Comprehensive Spending Review announcement on 20 October, Alliance Chairman Loyd Grossman commented:
“Yesterday’s announcements show that government as a whole still doesn’t quite ‘get’ heritage. Our heritage is among our greatest national assets yet also fragile and irreplaceable. It is vital that central and local government supports the framework to deliver the social and economic benefits that heritage brings and through which our members - the non-government heritage organisations - can fulfil their potential in caring for our heritage now and to inspire future generations.
“We fear that the immediate and longer term impact of a 32% cut for English Heritage and reduced funding from Local Authorities combined with the wider economic climate will lead to irreversible deterioration and loss of our heritage, stacking up huge bills ahead and eroding public support.
“We will be working with government to mitigate the impacts through partnerships, supporting social action and community responsibility. The pressures on the non-government heritage bodies will escalate but there is huge public support for our heritage and our challenge now is to turn that passion into practical inventiveness and enterprise.”
For further information on the CSR and reactions from across the sector:
Secretary of State’s Written Statement 21 10 10 http://www.culture.gov.uk/news/ministers_speeches/7508.aspx
Departmental press notices 20 10 10 http://cdn.hm-treasury.gov.uk/sr2010_pressnotices.pdf
DCMS: Secretary of State’s Written Statement 21 October 2010 www.culture.gov.uk/news/ministers_speeches/7508.aspx
English Heritage: Settlement Letter 21 October www.culture.gov.uk/images/publications/Andrews_-_english_heritage.pdf
English Heritage statement http://www.english-heritage.org.uk/about/news/eh-responds/Public-sector-cuts/
Churches Conservation Trust http://www.visitchurches.org.uk/news/csr/
National Heritage Memorial Fund http://search.hlf.org.uk/NHMFWeb/LatestNews/NHMF+statement+on+Government+Spending+Review.htm
Arts Council http://www.artscouncil.org.uk/news/arts-council-responds-296-cent-funding-cut/
Museums Association http://www.museumsassociation.org/museums-journal/news/20102010-comprehensive-spending-review-museums
National Museums Directors’ conference (NMDC) http://www.nationalmuseums.org.uk/news/?item=government-recognises-value-national-museums
Visit Britain http://www.visitbritain.org/mediaroom/pressreleases/csr20oct.aspx
Education cuts http://www.bbc.co.uk/news/education-11583990
Come on the heritage sector; let’s really blow our trumpets this year!
The Heritage Alliance Heroes Award scheme celebrates the energy and achievements of heritage volunteers amongst the Alliance membership. The Award, which is open to Alliance member organisations and their members, should showcase an inspirational project that was completed in the past 12 months by a volunteer individual or team (professional work is not excluded if funded and managed by volunteer effort) where the project has had a long-term impact and commanded the respect of the sector.
We’re particularly interested to hear about projects that are likely to appeal to a wider non-heritage audience and offer a powerful human story, which we can tell to the nation.
Applying couldn’t be easier – please submit a short nomination, with one image that encapsulates the project, by email before 30 June to Alliance Trustee Denis Dunstone firstname.lastname@example.org Enquiries also to Denis please on 02795 941595.
Entries will be judged by The Heritage Alliance Chairman, Deputy Chairman, two Board members and CEO. Their decision is final. The winner will be notified by 30 September. The member promoting the winner will be asked to produce a maximum five minute slide show or video showcasing the achievement for presentation at The Heritage Alliance’s AGM & Heritage Day in December 2012. The winner will also receive a memento of the event.
At last, the Statement on the value of the historic environment - with formal support of all Departments across Whitehall - has been published to complement and underpin Planning Policy Statement 5 and the PPS5 Planning Practice Guide. Until a Heritage Protection Bill is passed, this suite of value statements is the benchmark for the protection of our heritage for the foreseeable future. Is it enough?
The Alliance welcomes the Government’s Statement. It follows in a long line of declarations: A Force for our Future (2001), Better Places to Live (2005), and World Class Places (2009). But this one catches up with the popular interpretation of our heritage; the benefits and solutions it brings to 21st century life.
“The Government believes that the historic environment is an asset of enormous cultural, social, economic and environmental value.” As well as the acknowledgement of intrinsic value, the ways in which historic environment can help Government achieve many of its broader goals are spelt out. The Statement recognises that the iconic buildings and monuments, cathedrals and castles are only a small part of the historic environment: “Our history is equally reflected in the homes of ordinary people, in the street plans of historic towns and cities, in farm buildings and factories, in our public places, the landscapes we have created and the sites beneath our seas”. And “the historic environment should be seen as a vital contributor to improving the quality of place and quality of life for all”.
Significant also is the understanding on page 1 that “By promoting the inherent sustainability of historic buildings and their surroundings and by learning from them and the other types of evidence left by the low carbon economies of the past, we can make real progress in helping to mitigate and adapt to climate change.”
The test for the Statement will be how these warm words are interpreted by other Government Departments whose policies impact directly or indirectly on the historic environment. Phrases like ‘Intelligent management’ and ‘strong and effective partnership’ need to be translated into reality. While the voluntary bodies, owners and developers are expected to play their part, the Government sets out its own six strategic aims - strategic leadership; protective framework; local capacity; public involvement; direct ownership; and sustainable future.
It is up to us all to hold this and future Governments to account; to quote the Statement and to exploit that aspirational first line of the Vision “that the value of the historic environment is recognised by all who have the power to shape it”.
For the Vision Statement, visit: http://www.culture.gov.uk/reference_library/publications/6763.aspx
Sector responses to the Vision Statement:
The minutes are now ticking away for the reform of Common Agricultural Policy which could have a huge impact on future land management after 2013, including the survival of designed landscapes, archaeological remains, traditional farm buildings, as well as landscape features such as dry stone walls and field patterns.
The Heritage Alliance has taken the initiative to bring together heritage bodies, wildlife and countryside organisations in order to try and form a view of the way in which the CAP could be used after 2013 to influence the nature, the role and the character of the countryside. This initiative has been taken up at European level by Europa Nostra at a meeting in Brussels of heritage and countryside organisations on 25 March.
What is it all about? See
The Common Agricultural Policy and the Historic Environment
The 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: