Whats Good about PPS5

[drpeterwardle]

Sorry for not posting on BAJR for the last few months – I have been very busy.

So what’s good about PPS5? There are a few things that are a bit rough around the edges and there are some things which are having the opposite effect to what government intended but overall I am pleased with how the system has evolved. This increase in the amount of work for us is of course good and while this will take a while to filter through to excavations this can be no bad thing (unless of course you have to pay for it).

The most important thing for me is the requirement for a conservation statement for any substantive alteration on a listed building. This will also have the very effect government wanted in reducing the number of failed listed building consents.

When the 1979 Act came in there was much disquiet about its provisions and I can remember sitting in a site hut discussing it with the late great Phil Barker and him suggesting the whole of Britain should be treated as one big Archaeological Area. When PPG 16 came in I was present at the conference when the minister made the announcement and I, like most people in the audience, was very angry that there was not going to be a law change. Once the draft version of PPG 16 came in I was totally amazed about what could be done without a law change.
PPS 5 was drafted to accompany a new Heritage Act which was axed and I think the things that are causing difficulties are due to this fact.

What I am trying to do is to isolate what elements of PPS 5 are good, sensible practical things and so can people remember this when posting. Once we have isolated the things for which there is a consensus that they are good we will have a thread about the things which are bad.

One clear difficulty is the way it is being applied differently in different areas. Another is the slowness of Central Government to recognise that PPS 5 has come in and how it has come about. David and myself have discussed the thread and for once we want a bit of structure to the discussions. We hope it will produce a number of useful debates and hence why we think we need some kind of structure.

Peter

[BAJR]

David and myself have discussed the thread and for once we want a bit of structure to the discussions. We hope it will produce a number of useful debates and hence why we think we need some kind of structure.

Indeed we have and perhaps it is good to lead a debate - in a more formal manner, with an agreed consensus at the end.

So what’s good about PPS5, such a broad start to the discussion, but one that perhaps starts from the premise that there is good from PPS5. WE should consider the benefits, after all, we often complained about PPG16 did we not, so therefore have now hopefully taken a step forward. Is it perfect? of course not, however, it does seem to have placed many developers on the defensive, which to my mind is not the best place to start from, so where does PPS5 take over, where does it succeed. As Peter said, the loss of teh Heritage Act had a detrimental effect on the PPS, however it is here, it is now being acted upon, so how does it work for you?

The idea of creating sub debates is a good one, once we can work out what there is to debate. So tell me. What does PPS5 do for you?

[kevin wooldridge]

In this time of proposed local government staffing cuts, I would like to know what progress is being made in formalising the positions of HERs (and obviously HER staff). I imagined that this would provide employment for more than a few archaeologists, but I have yet to see a single advert for a position that might have been created as a result of PPS5. What's going on here (apologies if there is loads happening, bubbling under so to speak, I am not always up to date with goings on in UK archaeology)...

[drpeterwardle]

Kevin,

I doubt PPS 5 will cause many ads for new HER/SMR officers, virtually all HER/SMR holders have such a post with a person in post already. PPS 5 calls for a check on the HER/SMR, this is a basic step but..........
1. How far is this necessary in every case? clearly it is if there is an archaeological component but.....
2. How far are the charges made by HER justified when the HER officers are paid so little?

I will start a thread called PPS 5 debate agenda where we can suggest things that should be debated.

Dr Peter Wardle
(Putting SMRs on a statutory footing is Liberal Democrat Policy so as we are part of government an obvious good change to PPS 5 would be adding clarity by saying all LPAs must have access to an SMR and it is thus a requirement to fund them. At ?90 per hour you dont need many searches to pay for an officer to do them so how far is this necessary?)

[vulpes]

there are some things which are having the opposite effect to what government intended

That's an interesting statement Peter, which things would they be?

As regard the checking of the HER in relation to planning proposals etc. How you go about this is not specified in PPS5 and I suspect curatorial perceptions differ widely. I myself, speaking as a curator, would hope that this would mean informal pre-application consultation with the Development Control archaeologist for which there would be no charge for initial advice. That is, I don't see why this should necessarily constitute an additional financial burden on developers, it will generate more work for LG archs and the money will have to come from somewhere. HER search costs are certainly not 'going away' given the current climate in local government, and to be realistic Kevin I expect to see an overall reduction in local government archaeologists of all colours over the next 3 years (and indeed local government employees full stop). This appears to be a more evidence based summation of Liberal and Tory policy.

In general I see PPS5 and it's language as a 'good thing'. It does set some new challenges to the profession, across the board, and has already changed the way I work (and particularly how I justify my decisions). The clauses in HE12 specifically HE12.3 are especially significant and re-establish archaeology as a discipline that should aim to advance knowledge, not just collect stamps. :face-approve: Given noises from the new regime I'm not sure that PPS5 will be with us for much longer, though I hope that the good bits are at least kept in the new, streamlined, localised planning system.

Well, enjoy your debate. Thought I'd grab the opportunity to insert 2p before the IfA and curator kicking takes over as per.

[GnomeKing]

i agree that the wording does seem to emphasise knowledge - somewhere there is a statement about things being "sufficiently understood" rather than just "sufficiently recorded" - i am not too knowledgeable about the detail of the legislation, but it seemed that there is a degree of 'expert subjectivity' built in, so that material must be understood (even, heaven forbid researched!).

This perspective does a lot to change Temporal Waste Removers into technically skilled Earth Surgeons....however it is predicated on the presence of knowledgeable people in the right places....loss of LG/EH jobs is therefore a threat to effective operation of PPS5?

[drpeterwardle]

Slightly off topic but the EH press release on how the cuts will affect them http://www.english-heritage.org.uk/about/news/funding-englands-heritage/ says

"Following the Government announcement of a 32% cut to the grant of English Heritage, Commissioners have determined that in the national interest we will protect:
? our planning advice services, especially given the cuts in local authority funding;
? designation, ie identifying our heritage and protecting it by listing, scheduling and so on, which is a core activity no one else can do;
? the maintenance and conservation of our properties which we have a responsibility to look after for future generations;
? all existing grant commitments"

It has to be assumed that the EH planning service will be unaffected, how far the same is true for councils remains to be seen - I will add this to the agenda.

I agree the emphasis on an evidence based system and research is a good thing. Stopping archaeology being temporal contamination removers is to be welcomed. In one of my BAJR conference papers I called for the ology to be put back into archaeology I think PPS 5 goes some way to doing this. Is this something that we can all agree on?

Yes PPS 5 should lead to more pre-application consultations but given that many LPAs charge for this or won’t do them at all I suspect this is a difficulty. The core message of PPG 16 was cooperation not confrontation and early consultation. I am unsure if removing this clause is a good or a bad thing.

Yes the planning system is going to go through a major shake up and who knows what will happen. I think this is long overdue. Making the planning system more democratic is a good thing.

Peter
(But I would say this being a Liberal Democrat. And yes can we avoid the IFA/Curator bashing.)

[Dinosaur]

...Well, enjoy your debate. Thought I'd grab the opportunity to insert 2p before the IfA and curator kicking takes over as per.

Well I enjoy your contributions anyway, and that one was quite interesting (I thought so anyway) :face-approve:

Has anyone had to judge a Heritage Asset on its 'artistic interest' yet? If so, how the h*** does that work? Am waiting with baited breath for my first DBA where I can work that one in }

[drpeterwardle]

Judging an Ancient Monument on its Artistic Merit is nothing new - something can be scheduled for its artistic merit. This clarrification of why a heritage asset is important is surely something that is good about PPS 5. Yes I have had to do this. The downside of this section of PPS 5 is that the definition of what can be protected covers two separate and diffferent Acts the 1979 Ancient Monuments and Archaeological Areas Act and 1990 Planning (Listed Building and Conservation Areas) Act to my mind this is the biggest single problem that arises from the fact that there has not been a new Act and is something already on the aggenda for the PPS Bad debate.

Peter

[beamo]

How about the requirement under Policy HE6.1 for all planning applications to include a heritage impact assessment - either in the Design & Access Statement if one of those is rerquired, or as a separate document if there is no D & A Statement.

I work within a large planning consultancy and have seen this being applied in a fairly inconsistent manner as would have been expected. Some LPAs do not seem to have noticed this policy reqirement at all, others want a heritage impact assessment with absolutely every application no matter how small the development (and are therefore in line with the policy), some are selective in requiring this assessment but on no logical basis, some are refusing to register the application if there is no heritage impact assessment (and are therefore in line with the policy), some are registering the application but then stopping the clock until the heritage impact assessment is submitted.

Are there any curators out there who can provide a view on what is happening in their area?

Beamo