Thursday, 5 April 2012

Slimming is good – but for planning guidance?

In a week of granny tax, #cash4cameron, pastygate and empty petrol pumps the government seemed to get one thing relatively right and managed not to alienate people – and in this case their core constituency, the middle class and upper middle class affluent villagers in the Home Counties. The National Trust had been collecting names onto their petition and asked people to write to their MPs in order to ensure a better deal for British countryside and its protection than seemed to be the case in the new slim-lined planning framework. They were one of the most vocal parties opposing the wording of the draft guidance that had been circulated among different stakeholders as part of the consultation process. They seem to have been successful and in their press release after the publication of the new policy framework they called it “disaster averted”.

Greg Clark, the friendly face of government (Crown copyright)

Development archaeology had been following Planning Policy Guidance note 16 (PPG16) until last year when the Planning Policy Strategy for Historic Environment (PPS5) was published. However, the new National Planning Policy Framework published on March 27 ended 22 years of separate archaeological guidance within the British planning system. Many archaeologists had been expecting the worst since in the draft version the definition of “sustainable development” seemed to have been redefined from the previous guidance that emphasized the need to protect and use natural resources economically to a more economy-driven definition. After all, the coalition government, even if it promised to be the greenest ever, has lately been looking for growth in some form or shape more and more desperately.

The new national policy has been at least partly welcomed. As RESCUE says in its response: “the Government’s framework brings together what they consider to be the principle keystones of sustainable planning and development into a single integrated format. It should be gratifying for all who work within the heritage profession to note that, finally, the historic environment has taken its place at the top table alongside the natural environment, transportation, climate change and all the other central pillars that support sensible planning policy.”

In principle, if the historic environment is one of the core provisions of planning policy, this should be an advantage. Archaeologists can now argue that the existing historic environment planning advice services are within the core of the planning process and we as a profession could lobby for an effective network of statutory local authority teams made up of archaeologists, historic building specialists and landscape advisers. The framework clearly states that “local planning authorities should either maintain or have access to a historic environment record” and where appropriate prepare landscape character assessments. Despite this RESCUE thinks that the NPPF represents a weakened policy provision for the historic environment. The NPPF emphasizes the protection of designated features when the majority of British archaeological sites and historic structures are not such things. There are also terminological issues with “heritage assets”, “significance” and “advancing understanding”, inherited from the short-lived PPS5. RESCUE has stated that it cannot commit to this framework.

Dr Mike Heyworth , the Director of the Council of British Archaeology (CBA), on the other hand stated that the NPPF reflects a more balanced approach to sustainable development than the draft framework. In addition, the importance of the Local Plan is presented as the strategic envelope for neighbourhood planning. Nevertheless, he doubts if a year will be a sufficient time frame for local planning authorities to put their plans in place. Some people have also suggested that the slim national policy will mask the likely-to-be bloated local development plans and guidance notes. In addition, with the local government cuts and reductions in the numbers of archaeologists it is unclear if the safeguards will be – even for the designated archaeological sites – sufficiently robust. However, the new policy makes the Historic Environment Records a requirement, which may help the suffering services.

RESCUE and CBA as non-governmental organisations are in a more ‘objective’ place than English Heritage is as a governmental organisation. English Heritage believes that the level of protection will be the same as it was with the PPS5. Even if heritage will continue to play a central role in long-term sustainable growth, the present cuts give them concerns. Thus the organisation will monitor the implementation of the policy and see if it will be implemented swiftly at the local level with good quality local authority expertise widely present.

Institute for Archaeologists (IfA) as our professional institute finds a lot of good in the new framework but is very concerned about the continued emphasis on economic growth and the preference for development unless its adverse effects ‘significantly and demonstrably’ overweigh the benefits. They also hope that the new guidance and further government response will make the local government to support sufficient professional historic environment advice services. Of all archaeological organisations BAJR Federation had not commented on the NPPF during the week of its publication on its news page although there is a thread on their discussion board based on the repeats of selected sound bites from the government and the IfA.

When reading the new document it is painfully clear that all emphasis is on development. Its overarching title is Achieving sustainable development and the minister in charge declares that “Development means growth”. The government concludes that “our historic environment – buildings, landscapes, towns and villages – can better be cherished if their spirit of place thrives, rather than withers”.

Although one of the roles of the sustainable planning system is to protect and enhance the historic environment, at the same time the government tries to create more jobs as it wants to increase biodiversity, improve design of built environment and improve the conditions where people live, work, travel and take leisure. This is very much inspirational and motivational speech and the reality will be revealed with the future implementation. It is worth noting than when there is no Local Plan in place the planning permission will generally be granted unless there are significant adverse effects to the population, social thread and natural and historic environment. Special policies suggest which areas should not be developed and these include “designated heritage assets” (unless the benefits overweight the losses).

The NPPF has about two pages on historic environment and the finer reading of the wordings, partly copied from the PPS5, is quite surreal and the government comes across as confused. The framework states that Local Plans should recognise the nature of heritage assets as an irreplaceable resource and conserve them in a manner appropriate to their significance. However, "local planning authorities should not permit loss of the whole or part of a heritage asset without taking all reasonable steps to ensure the new development will proceed after the loss has occurred". Does this mean that the lost asset has to be reconstructed after the loss or that the building works have to continue despite such a loss (and the developer must not be prosecuted)? The section suffers from the simultaneous will to develop and preserve; many paragraphs require multiple readings in order to ascertain if the sites will be totally protected or developed on the basis of this framework. The paragraph 133 is especially tricky since it seems to imply that if a heritage area cannot be used, marketed or managed by a charity and a more beneficial use can be found the loss will be accepted – no matter if it is a designated area or not.

The government is also setting the environment for the development of Stonehenge and new buildings in Liverpool by stating that “local planning authorities should look for opportunities for new development within Conservation Areas and World Heritage Sites and within the setting of heritage assets to enhance or better reveal their significance”. If read cynically this section suggests that ultimately no conservation area is safe. Yes, it facilitates repairs and technical improvements but suggests that the areas can be endlessly scrutinized and fragmented under possible bad management. Together with the spirit of the paragraph 133, Stonehenge could be demolished to build a motorway if the use will be deemed more beneficial and the benefits outweigh the loss. Luckily, Stonehenge creates tourism revenue and most world-class sites can serve as pasture if nothing else. However, the wordings give way to possible tugging and towing and some very cynical interpretations.

The communities are advised to engage in the planning process through the local development plans and are invited to find opportunities for enabling development. This wording does not really empower local communities since the authority who has the right to make judgements of significance and importance and the possible adverse effect to local communities has been left undefined and thus is unlikely to be local although the framework introduces local referendums. The neighboroughood plans are to be drawn up by the parish councils, which will mean that they will end up creating wordy documents the NPPF tries to avoid. In the glossary and in the planning process description the framework mentions the neighbourhood forums, which as unelected stakeholders will in the worst cases provide an arena for the powerful or the loudest. Traditionally communities tend to be against high-speed rail networks and large new towns and in the face of the reality the coalition government clearly tries to enforce positivity. One assumes from between the lines that ultimately the government will define the ‘sustainable development’ and impose the development opportunities onto the communities. On the positive side all things need to be improved eventually and it is healthy to try to look for development opportunities in order to avoid future disputes. Furthermore, archaeology needs development in order to sustain employment and well-excavated sites improve our knowledge of our history. Sadly, we all know that very few people dream of an industrial site, a new estate or travellers’ site as their new neighbour.

It is clear that the assessment of significance and importance of any heritage asset will require further guidance in the future. In other countries with stronger heritage laws there is usually a classification system in place that creates the framework for defining the truly significant sites that should not be developed and those that will be studied to a sufficient degree before any development. This future guidance will clearly be wordier than the policy framework, which suggests that this new publication only creates more paperwork at the lower levels of the food chain.

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