PPS Consultation

[BAJR Host]

After reading the whole document and looking at the consultation questions I was struck by more what was missing rather than what was in. Leaving aside the wishy washy "should" that seems to pervade the document, there is a clear sign that no archaeologist actually looked at/advised it before this draft.
http://www.communities.gov.uk/publicatio...istoricpps

Take for example the EH Guidance that should accompany it.
http://www.english-heritage.org.uk/uploa...1256968187

New discoveries during work
66. When, during development, a new discovery arises that could not reasonably have been foreseen at the time of application, the local planning authority is advised to work with the applicant to negotiate a solution which protects the significance of the new discovery, so far as is practical within the scheme. The importance of the discovery will have a bearing on the extent to which the local authority wishes to require modifications to the proposals. The new evidence may cause the local authority to consider reviewing the decision. English Heritage would wish to be informed if the discoveries are likely to merit designation.

well, thats gonna happen!

I can just see the developer going... er...this new archaeology I found, I better report it to the council so they can review my planning conditions!



Taken as a whole there is much to be comended in the PPS... however I notice no mention of the IfA Guidance documents on watching briefs or other investigations which are now seen as standards. I see on page 19 of the Practice Guide that "Further guidance on how to prepare a written scheme and ensure its objectives are met is available in the English Heritage publication Management of Research Projects in the Historic Environment (2006)." Well hells teeth... that needs to be carried out and be checked by a planning archaeologist... NOT anyone sitting in a council planning department with a handy guide.!

There are so many holes I can'y enumerate them... It seems to mostly deal with buildings, and in the PPS the same is true with so much leaway as to make it difficult to pin anything down. The loss of teh Heritage Bill - which would have supported the PPS is a disaster... rushing this through would be bad. And the sad thing is... it will be.

There are however many glimmers of hope...

"64. The process of investigation and recording, such as dismantling a building, or excavating a site, may be of public interest in its own right. Where appropriate and possible, local planning authorities may wish to consider the public benefit of making the investigative works open and interpreted to the public and requiring that as part of the written scheme of investigation. For example, this dissemination could include viewing platforms and interpretation panels as well as seeking coverage in the local newspaper."

and this is within the PPS... BUT... how is that and when is that to be implemented...? Hands up anyone who can cite Public saftety as an issue.. or confidentiality etc etc.....

All is all, this needs a massive rewrite before it needs full consultation.


Here is a fave

"The archive can be offered to a suitable repository, such as a museum, county archive service, or an expert institution who may be very willing to take it." who may be willing to take it....BUT who is going to pay for it?

Anyway... it is a step forward from the well intentioned but ultimately (look where we are now) flawed PPG. I would like to see a revised edition before anything moves into final print. Many others have responded... I felt that as BAJERites.. it was not ready and would only muddy already muddy waters.

see the CBA
http://www.britarch.ac.uk/sites/www.brit..._final.pdf
and Rescue reponses
http://www.rescue-archaeology.org.uk/bet...sultation/


what you think? :o)

[BAJR Host]

I think Elvis says it best. click play!

http://www.vomrheinland.com/media/Elvis_...sation.mp3

[YellowPete]

keep your fingers crossed that its not all just talk, but has practical merit
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[BAJR Host]

:face-angel: I could not possibly comment!

[gilescarey]

Hi David
Just to correct Rescue link, this one is for another DCLG consultation.

I have just put the Rescue response up. Our comments were similar to your line of thinking:

http://www.rescue-archaeology.org.uk/bet...vironment/

or...

http://www.scribd.com/doc/21985885/PPS-1...e-Response

Cheers

[ex-archaeologist]

I also noticed the bit about public involvement (copied below from Davids post). I suspect that it is related to government efforts to involve the public more in the planning process in order to create 'a sense of ownership', as this is one of the major issues in planning at the moment.

I think the key word here is 'where appropriate', which clearly if safety is involved, it won't be.

I haven't read PPS15 for a couple of months so my memory is a little hazy. It talks about the need for 'pre-application consideration', as opposed to PPG16's 'pre-determination' emphasis,pushing archaeology a little further forward in the system, presumably this relates to the tighter timetables which planning authorities have to work to in considering applications. The effect of this should mean that evaluations and DBA's will be undertaken earlier in the process, which is no bad thing.



"64. The process of investigation and recording, such as dismantling a building, or excavating a site, may be of public interest in its own right. Where appropriate and possible, local planning authorities may wish to consider the public benefit of making the investigative works open and interpreted to the public and requiring that as part of the written scheme of investigation. For example, this dissemination could include viewing platforms and interpretation panels as well as seeking coverage in the local newspaper."

[BAJR Host]

@ex-archaeologist. I think thats the nub of this document.. it is in general 'not a bad thing' where it falls down (imho) is the detail, the mechanisms, the definitions. What is significant? When is it appropriate? where is the standard? Who pr

[ex-archaeologist]

I thought people might be interested in this article which has just been posted on Planning Resource, detailing the Royal Town Planning Institute (RTPI) and the IHBC's joint response to PPS 15.

I also include links to the full planning resource article, the full RTPI/ IHBC response (60 pages) and the IfA's response. The RTPI has 22000 members (and a Royal charter), the IHBC 1700 and the IfA 2800

RTPI slams heritage review plans

The RTPI has described the government's review of PPS15 as a "charter for people who want to knock buildings down."
In its response to the consultation on the draft plans, which closed on Friday, the RTPI says it is unhappy with the proposed changes and without significant and substantial changes in the PPS, we think it will not be fit for purpose.

Martin Willey, President, Royal Town Planning Institute said: "This could prove to be a charter for people who want to knock buildings down because it is the cheapest option for them. The biggest problem with this new guidance is that it assumes that heritage stands in the way of development and economic recovery, which is patently untrue. Historic buildings and places are an asset not a burden."

Sean O?Reilly Director, Institute of Historic Building Conservation said: "The PPS relies too much on a narrow way of judging how important our heritage is to everyone. The way it proposes to judge significance marginalises our heritage to an academic judgement and ignores the contribution of the built environment to making better places for communities."

The Full planningresource article can be found at:

http://www.planningresource.co.uk/bullet...lyBulletin

The Full RTPI/ IHBC Response is at:

http://www.ihbc.org.uk/news/docs/IHBC_RT...291009.pdf

The IFA Response is at

http://www.ihbc.org.uk/news/docs/IfA_res...tation.pdf

I must admit that I have not had time to read them all yet.

[BAJR Host]

Nice one... thanks for that and thats a nights reading ahead!!

[BAJR Host]

said of the draft policy:

The new PPS is another in the right direction towards a 21st century planning system where the historic environment plays a central role. If the Government listens to the comments of the heritage sector on the consultation draft and develops its policies to benefit from our expert contributions then we believe that the PPS will represent a positive and welcome advance for heritage protection in England to maximise the public benefit and appreciation of our nation?s heritage.