PPS15 – PLANNING FOR THE HISTORIC ENVIRONMENT

Some notes on the presentation of this Consultation Paper

in London 4 August 2009

 

Introduction

When the Heritage Protection Bill was delayed, both the Government and English Heritage claimed that much of its content and purpose could be implemented through current legislation. PPS 15 is start of this process.

 

This Consultation Paper (responses by 30 October 2009) has been jointly prepared by the Government (DCLG & DCMS) and English Heritage with the objective of upgrading heritage protection, using existing legislation.   Like the proposed Bill it aims to combine, improve and up-date pieces of existing guidance – in this case PPG15 (Planning and the Historic Environment) 1994 and PPG16 (Archaeology and Planning) 1990.  The presentation reviewed both the draft Planning Policy Statement (www.communities.gov.uk/publications/planningandbuilding/consultationhistoricpps) and the Historic Environment Planning Practice Guide to PPS15 prepared by English Heritage (www.english-heritage.org.uk/server/show/nav.21136).

 

It should be noted that both documents are directed at Local Planning Authorities (LPAs) to advise and guide them on the protection of our historic environment when both plan making (LDFs., Action Area Plans and Policies) and in development control.  Two key points seem to guide the policy:

  • All the elements of our historic environment ie. buildings, archaeology, battlefield sites, parks and gardens and maritime sites should dealt with in one policy rather than through a separate policy for each element, and
  • That “we should focus on what is significant in heritage terms about a place and not just protect all of it for its own sake”.

 

The following notes and comments are directed at members of AGT and the county gardens trusts and therefore I will concentrate on proposals affecting listed historic parks and gardens and landscapes.

 

PPS15

The key parts of this document are Part 1 and Annex A : Planning for the Historic Environment. Following an introduction by Baroness Andrews (Chairman of EH) some key points were made by Ruth Marshall from DCLG viz:

  • The PPS accepts that there are conflicting pressures between supporting economic development, climate change and the historic environment – yet heritage  has a role in economic development/regeneration;
  • A major need is the active involvement of local communities;
  • “The historic environment needs to be part of this vision (of a future for places and communities), and reflected in priorities, investments, and delivery plans”.
  • The objective is to simplify and reduce delays by:

-       separating policy from guidance;

-       defining where a policy must be followed and where there are options for local flexibility;

-       clearly defining the evidence needed to make robust decisions.

 

Duncan McCallum, Policy Director for English Heritage then gave two clear presentations:

 

1.    On the PPS 15

Policies : Policy P 4 is useful as it determines that “heritage assets” can include those “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”  the net of potential heritage protection can be extended.

 

Another important activity being encouraged is the contribution to knowledge ie. recording information as part of the plan/decision making process before heritage is at risk of being lost.

 

Plan Making Policies:

  • HE1 - Build an evidence base ie research
  • HE 2 & 3 – identify the positive contribution that heritage assets can make and encourage their active use;
  • HE5 – the removal of permitted development rights under Article 4 Directions can be applied to heritage sites as well as Conservation Areas;
  • HE8 – an applicant must supply sufficient info. to assess the significance and the Local Authority (LA) should take account of expert and local views.
  • HE9.7 – where a development proposal has a negative impact upon the significance of the heritage asset, either directly or through development within its setting the Local Planning Authority (LPA) has to weigh the public benefit (if any) of the development against its adverse impact ie. the greater the harm the stronger the justification that will be needed;
  • HE11 – a warning that the setting of an asset (ie the parkland or historic garden) may enhance the basic asset and therefore inappropriate development within the setting will adversely impact on its significance.
  • HE13 – principles guiding the recording of information about the asset. The policy states that the info collected and supplied to the LPA should be published and put into the Historic Environment Record (HER) and offered to local museums etc.  I pointed out that from the Trust’s experience some landowners object to publication of information about their parks and gardens (theft of ornaments, statuary, plants etc.) – it was agreed to look at this.

 

  1. The Planning Practice Guide

The PPS is the “must do” and the Practice Guide is a suggested route to implement the policies. The presentation, and the guide, both clarify and comment on the draft PPS.  Of importance is the definition of “significance” – a key factor in determining the importance (and therefore the need for preserving) of an asset. Annex 1 defines it as “The value of a place to this and future generations because of its heritage interest.  That interest may be archaeological, architectural, artistic or historic.”

 

Some relevant (to AGT and CGTs) parts of the guide that I have noted are:

Re Policy HE1  - “ the Register of Parks and Gardens of Historic Interest is thought to represent around two thirds of potential sites” – from the experience of Hampshire I would have thought that EH listed sites are about 25% of the total.  The Guide advises that “additionally (LAs should) compile a “local list” of heritage assets judged by objective and publicly consulated criteria to be of heritage interest”.

 

I would draw readers attention to Part 4 of the Guide relevant to making changes to Heritage Assets. It is useful to read the original, but some key items of interest are:

·         Landscapes are defined as both extensive and smaller scale, including, but not limited to, designed and ornamental or recreational landscapes.

·         Good conservation is founded on appropriate routine management and maintenance…. and is therefore encouraged for all owners.

·         Paras. 79 & 80 (pp.24) deal with repair, maintenance and restoration of landscapes.  I’m not sure that the preservation of our historic asset should mean only back to its original. We should allow for some changes to historic parks and gardens to ensure that they can be continue to be used in the 21st century.  Certainly I have recently seen successful examples of this in Hampshire.

 

Conclusions

These “notes” have become rather lengthy, but these are important documents to direct and guide LAs (and especially LPAs).  May I recommend that all Trusts at least read the 24 page Guide produced by EH – downloadable from their website. The PPS 15 document (also downloadable) is 73 sheets long although in my opinion the first 24 pages are the most important to us.

 

At the AGT AGM (Business Meeting) in Lincoln last weekend, I offered, as a member of the AGT Conservation Group, to produce a response to the consultation (before 30 October).  However to ensure that it reflects all opinions of AGT I will need to receive inputs from other Trusts well before the end of October!

 

 

 

Tony Hurrell

Chairman, Conservation Committee, HGT

Member Conservation Group, AGT

16 August 2009 (rev. 8 September 2009)