PPS15 Draft Consultation

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The Questions:

Questions on which we would particularly like your views:

1. Does the PPS strike the right balance between advocating the conservation of
what is important and enabling change?

2. By adopting a single spectrum approach to historic assets, does the PPS take
proper account of any differences between types of asset (eg. are archaeological
assets adequately covered)?

3. In doing so, does the PPS take appropriate account of the implications of the
European Landscape Convention, and of the cultural dimensions of landscapes
designated as National Parks and Areas of Outstanding Natural Beauty?

4. Are the policies and principles set out in the PPS the key ones that underpin
planning policy on the historic environment, or should others be included?

5. Do you agree that it is the ?significance? of a historic asset that we are trying to
conserve?

6. Does the PPS comply with devolutionary principles with regard to what is
expected at regional and local levels?

7. Does the PPS strike the right balance between the objectives of conserving what
is significant in the historic environment and mitigating the effects of climate
change?

8. Does the PPS make it clear to decision-makers what they should do, and where
they have more flexibility? Are there any risks or benefits you would like to
highlight for the historic environment sector?

9. The draft PPS highlights the importance of ensuring that adequate information
and evidence bases are available, so that the historic environment and the
significance of heritage assets are fully taken into account in plan-making and
decision-taking. At the same time we are concerned to ensure that information
requirements are proportionate and do not cause unnecessary delays. Are you
content we have the balance right? If not how would you like to see our policy
adjusted? (Policies HE8 and HE9 are particularly relevant to this question.)

10. In your opinion is the PPS a document that will remain relevant for at least the
next 20 years? Do you see other developments on the horizon that have
implications for the policies set out in the PPS?

11. Do you agree with the conclusions of the consultation stage impact assessment.
In particular, have we correctly identified and resourced any additional burdens
for local planning authorities? Is the impact on owners/developers correctly
identified and proportionate to their responsibilities?

12. Do you think that the policy draft PPS will have a differential impact, either
positive or negative, on people, because of their gender, race or disability? If so
how in your view should we respond? We particularly welcome the views of
organisations and individuals with specific expertise in these areas.

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Extracts from Heritage Link newsletter includes some comment:

Draft PPS 15
Not a substitute for a Heritage Bill but a significant stage in updating heritage protection, PP15 will replace Planning Policy Guidance notes 15 and 16 both published in the 1990s and though much loved in a format no longer favoured by government. The PPS sets out 13 high level policy statements that will be a key ?material planning consideration? in determining planning applications and development plan documents. It is accompanied by a Historic Environment Planning practice guide from Engl;ish Heritage which details how the new principles might be applied.

It purports to maintain the same level of protection as the current PPGs 15 and 16 so what is different? There is emphasis on the principles of sustainable development. The PPS deals with all types of heritage in a single document. It puts more focus on understanding what is significant about a building, site or landscape so that it is ?easier? to determine the impact of the proposed change. The new PPS encourages the ?active exploitation? of heritage and the instrumental values of the historic environment as assets rather than allowing them be seen as potential barriers to development. It also fills in policy gaps with clearer policies on setting and design and gives greater clarity on topics such as archaeological interest, the preservation and enhancement of conservation areas, World Heritage sites, and on conflict with other planning priorities such as climate change. However while the Heritage Bill would have made it a statutory duty for all Local authorities to maintain or have access to Historic Environment Records, the PPS can only urge them to create publicly accessible HERs.

For the English Heritage summary and full documents including impact assessment see
http://www.english-heritage.org.uk/serve.../nav.21135

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and:

Draft PPS15: comment so far
The development press quickly pointed out that the very loose definition of heritage assets would cause confusion. The Architects Journal claimed critics were ?concerned that such a broad scope of coverage could give too much discretionary power to planning authorities?. Uncertainty would be compounded by widening existing policies to cover ?assets that are not currently designated or are not capable of designation under current heritage protection legislation, but which have a level of interest which should be conserved and, where appropriate, enhanced?. Thirdly the emphasis on pre-application discussions would make the process more complicated and onerous for developers because applicants would be expected to assess the ?significance? of heritage assets before the development is designed and the application submitted.

Some within the heritage sector have welcomed the publication as a step forward in the absence of a Heritage Bill. The Institute of Historic Building Conservation argues that while placing the historic environment at the heart of the planning system is welcome, the draft needs to show more appreciation of how it contributes to sustainable places. Meetings of the Historic Environment Review Executive Committee (HEREC) and the Joint Committee of Amenity Societies are also discussing its implications. The development of historic environment records as the main evidence base is generally welcomed and the recognition of the potential significance of undesignated assets but immediate reactions criticised the implied conflict with climate change, raised concerns over the emphasis on assets rather than place, and how the proportional approach, based on defining significance more closely would work in practice.

There is one area the voluntary heritage sector should consider carefully: the provision for expert advice set out in HE9 drawn from in house resources and complemented by specialist national organisations and local amenity societies and taking in accounts the local community. But the emphasis throughout on pre application discussion as the means of resolving conflict appears to exclude third parties. Unless there are opportunities in the whole process of protection for amenity societies and stakeholder groups to contribute their views at an appropriate stage, these will only emerge at the end when they can make little difference and their views are more likely to be considered obstructive.