Garden conservation
Enabling development and the conservation of heritage assets - Practical Guide to Assessment
The Association of Gardens Trusts
President: Mrs Gilly Drummond D.L.
Registered Office: 70 Cowcross Street, London, EC1M 6EJ Tel and Fax: 020 7251 2610
E-mail: agt@gardens-trusts.org.uk Web site: www.gardenstrusts.org.uk
Rebecca Fraser
Enabling Development
English Heritage
24 Brooklands Avenue
Cambridge
CB2 8BU
18th October 2007
enablingdevelopment@english-heritage.org.uk
Dear Ms Fraser
Enabling Development and the Conservation of Heritage Assets
POLICY STATEMENT PRACTICAL GUIDE TO ASSESSMENT
Consultation Draft of Updated Edition: July 2007
Thank you for consulting the Association of Gardens Trusts.
The Association agrees that up-dated guidance on enabling development should be a useful tool as we strive to conserve and sustain our historic environment.
The Association of Gardens Trusts was established as a charitable trust in 1993 and comprises 35 County Trusts in England, together with another 9 in Wales. We have over 7,500 members who actively support the care and conservation of our historic designed landscapes, parks and gardens for the enjoyment and education of all ages. We would also like to point out that our expertise does not extend to some of the detail in this document however we would like to make the following comments.
In our opinion this document covers the critical issues connected with enabling development. It is clear and easy to understand, however we are not planners and we do not have the practical expertise to say how well it can be implemented by local planning authorities.
An over-arching point relevant to this document in our view, is the need for the resources and the will at the local authority level to assess the listed building and landscapes stock in their area (1.2.5) and to identify those sites likely to become the subject of enabling development, to develop briefs and to generally be pro-active in this process (2.3.1). There is a requirement for more highly trained conservation officers and planners. We have too many local authorities without sufficient conservation expertise and this is to be deplored.
At 3.2.1 we support the point and the fundamental principle that planning permission should only be granted if the impact is precisely defined at the outset etc. We are particularly concerned that if care is not taken here then the park or garden could be seriously damaged. We would like to point out the harm that car parking and new hard landscaping for vehicular access, parking and other access routes can do and that the historic appearance can be seriously damaged if these points are not considered carefully at the outset. Sustainability and climate change issues should also be carefully integrated into the full planning permission to incur the least damage to the heritage asset.
At 5.16.3 we consider that approval for enabling development for the historic buildings should include repair and replanting of the landscape. We support the principle of requiring a long-term conservation management plan and that should be made clear to developers/owners at the outset and monitoring should be put in place.
We find the relevant appeal decisions very helpful as are the appendices.
The following are our comments to your specific questions:
Q1 Section 2.2 Setting out the English Heritage enabling development policy as a local development framework exception policy could be useful if it alerts potential developers of historic sites to the rigorous principles of enabling development and prevents damaging changes. However we would be concerned that exception policies could turn into what is permissible and thus be counter-productive in conserving our historic assets.
Q2 Section 4.7 We are pleased to see the inclusion of the issue of ‘historic entities’; an important consideration. In our view too the cultural value of the whole can often be greater than the sum of its parts and this is particularly important when it comes the combination of designed landscapes and gardens with historic buildings. Too often the historic landscape is sacrificed and damaged in order to seemingly ‘save’ the buildings. In so doing the aesthetic and cultural quality of the whole heritage asset is harmed. We are however concerned that at 4.7.5.1 the grades are limited to I and II*. With only approximately fifteen hundred Registered parks and gardens in England (as compared with four hundred thousand or so listed buildings), the grade II sites are still very significant and should be included in this document. As you will know there are many other historic parks and gardens currently not on the Register but shown in past studies to be of sufficient importance to merit inclusion that it would be helpful to include provision for these in the policies for ‘historic entities’. Some local authorities have their own regional and local lists of historic parks and gardens and these should also be considered under ‘historic entities’ policies.
Q3 Section 4.8 Although we do not have specific expertise regarding farm buildings we can understand and support the significance of retaining certain buildings and assemblages as important cultural elements within the countryside; a countryside that is undergoing such rapid change. Many farm buildings have been converted to residential use and this trend is of course continuing. Conversions vary in sensitivity and quality and every effort should be made to encourage high quality conversion so that the wider rural landscape is not further damaged. We agree with point 4.8.3.
Q4 Section 5.16 We agree with the guidance which stresses the desirability of normally discouraging the use of enabling development to fund restoration or enhancement beyond the minimum necessary to secure the future of a heritage asset.
Q5 and Q6 We are not clear that this updated draft Guidance includes policies to prevent post-enabling development applications that although seemingly of a minor nature, are cumulatively very damaging. In our view once the enabling development has been thoroughly discussed and granted then there should be a moratorium on further applications.
As noted at Q2 the document makes no mention of those parks and gardens that are of regional or local importance and these are the very heritage assets that are most likely to be damaged in the future and which unfortunately often have little or no protection. Could more use be made of Local Development Frameworks? Could local authorities be given more help and encouragement to define their local ’heritage’, which could then be subject to careful criteria for enabling development?
Finally we would like commend this draft document and also to re-iterate the need for resources to put it into practice. Otherwise these policies and guidance will not be used to their full potential and our heritage assets will suffer as a consequence.
Yours sincerely
Val Hepworth
Mrs Val Hepworth
Vice-president
