PPS15 Draft Consultation

[vulpes]

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.