Memorandum by English Heritage (AH 48)
EXECUTIVE SUMMARY
The scale of the proposed housing development
has important consequences for the historic environment. Our evidence
examines the challenges that that development poses for the historic
environment and sets out some issues that need to be addressed.
But the proposed development should not be seen as a threat to
the historic environment. Rather it should be seen as an opportunity
to realise the potential of the historic environment to create
new sustainable communities and reinvigorate existing ones. The
evidence concludes with some observations on the ODPM's Planning
for Housing Provision.
THE CONTEXT
1. English Heritage is the Government's
statutory adviser on all matters relating to the historic environment
in England. We are a non-departmental public body established
under the National Heritage Act 1983 to help people understand,
value, care for and enjoy England's historic environment.
2. The historic environment is all around
us and encompasses the whole of our historic landscape and buried
archaeology, not just visible buildings and scheduled monuments.
It is our most accessible cultural resource. It has a powerful
influence on peoples' sense of identity and civic pride. It contributes
significantly to the character and "sense of place"
of rural and urban communities. It is at the heart of sustainable
growth.
3. English Heritage accepts the need for
greater land-allocation for housing development and for the supply
to be made more flexible than at present to ensure that the right
houses are delivered in the right areas. English Heritage believes
that by ensuring decent homes for all this will enhance the quality
of life for many people and ensure they are able to better enjoy
the environment, including the heritage dimension.
4. The scale of the proposed development
has important consequences for the historic environment. It should
not be seen as a threat to that environment but as an opportunity
to make best use of its full potential to help create new sustainable
communities and reinvigorate existing ones. The historic environment,
properly understood, sensitively managed and intelligently developed,
can make a positive difference to the proposed housing development
programme.
HOUSING SUPPLY
CHALLENGES TO
THE HISTORIC
ENVIRONMENT
5. The historic environment is sensitive
to change. A number of issues need to be addressed in relation
to the scale of housing development to ensure the potential of
the historic environment is fully realised.
6. As a general rule, the emphasis should
be on regeneration, the re-use of brownfield land and achieving
high densities for new developments. In areas of historic environment
sensitivity, however, the densities should not be so high as to
adversely affect the heritage interest.
7. There is a danger that bringing forward
significant new areas of greenfield land will detract from the
reuse of previously developed land and result in the opportunity
of regeneration of historic settlements being missed.
8. Appropriate environmental assessment
of possible housing land (such as historic landscape characterisation
and archaeological evaluation) needs to take place and the results
taken into account before decisions are taken on whether to allocate
land for housing. In 2004 English Heritage published A Welcome
Home which applied these techniques to The Thames Gateway
and we are able to advise those wishing to undertake them elsewhere.
9. There is a risk in looking just at the
overall demand for housing and seeking to provide for it. English
Heritage is concerned that in attractive rural areas there will
be a considerable demand for homes and some distinguishing between
different types of demand might be advisable. Otherwise there
could be development pressure on National Parks and Areas of Outstanding
Natural Beauty and for the expansion of settlements that are currently
largely designated as Conservation Areas or which contain a high
proportion of listed buildings.
10. Careful consideration will need to be
given to the environmental constraints of local housing markets
as part of the overall assessment of the amount of land allocated
for housing. There is probably therefore some need to distinguish
between different segments of the market and to ensure that the
right kinds of home are delivered in the right places.
THE OPPORTUNITIES
OF HOUSING
DEVELOPMENT
11. English Heritage believe that housing
development provides an opportunity to exploit the potential of
the historic environment to create sustainable communities, places
where people want to live and work.
12. By focusing on what already exists and
understanding the unique and varied character of housing in each
part of England, we believe that new development can draw on that
special character and strengthen regional and local identity both
through highlighting the qualities of what already exists as well
as inspiring new development.
13. English Heritage believes that housing
growth developments should seek to connect with the past through
the reuse of historic buildings, public spaces and urban layouts.
Key historic buildings add quality and visual interest to a new
development. Through the use of imaginative, high quality design
and appropriate materials, new buildings can be stitched into
historic areas with an overall enhancement of local character,
while surviving older buildings can be reconnected with their
urban environment. New buildings which respond positively to their
historic settings and neighbours are popular and help to create
local identity which links a sense of continuity with the positive
welcoming of change.
14. The enduring success of many traditional
high density settlements suggests they might act as a useful model
for new development.
15. Re-use and adaptation of heritage assets
is at the heart of sustainable development. Throughout the growth
areas, English Heritage has been investing in conservation-led
regeneration. Examples include projects in Gravesend, Rochester/Chatham,
Forest Gate (Newham), Waltham Abbey, St Neots, Luton, Newport
Pagnell and Wolverton.
16. Re-using historic buildings is good
for the natural as well as the historic environment. The historic
environment represents embodied energy in the form of timber,
stone, bricks and glass. Research by the Building Research Establishment
has shown that a "typical" Victorian house contains
energy equivalent to 15,000 litres of petrol, which is enough
to drive a car five times round the Earth.
17. Statistics based on houses of different
vintages in Manchester, reported in Heritage Counts 2003, showed
that a Victorian house proved to be almost £1,000 per square
100 metre cheaper to maintain and inhabit each year than a property
from the 1980s.
18. Re-using historic buildings contributes
to the achievement of sustainable development targets for reducing
greenhouse gas emissions. It also reduces the use of new aggregates
for construction and reduces the amount of waste in need of disposal.
19. Relatively inexpensive improvements
can go a long way to making older homes more efficient and sustainable.
PLANNING FOR
HOUSING PROVISION
20. English Heritage responded to the ODPM's
consultation Planning for Housing Provision. We raised
a number of issues, some of which are summarised below.
21. English Heritage welcomes the recognition
of inevitable environmental impacts of new housing in the second
of the key principles in the consultation paper but is concerned
that the phrase "need to be minimised" is rather weaker
than the advice in paragraph 19 of PPS1 which states that: "Planning
authorities should seek to enhance the environment as part of
development proposals. Significant adverse impacts on the environment
should be avoided and alternative options which might reduce or
eliminate those impacts pursued."
22. In paragraph 28 of PPS1 it further states
"Planning authorities should seek to achieve outcomes which
enable social, environmental and economic objectives to be achieved
together." This is rather different in tone from the "minimising
environmental impact" approach of the consultation which
implies undue precedence being given to the supply of housing
over the effect on the environment.
23. English Heritage believes greater emphasis
needs to be given to the principles of achieving social, environmental
and economic objectives together rather than suggesting it is
a trade-off between them.
24. The Government's promotion of sustainable
development should be set out more explicitly. Development in
areas where there is little or no demand is wasteful of scarce
resources, but equally unconstrained development in areas already
under pressure can have a seriously detrimental impact on infrastructure,
the local environment, the character of historic settlements and
so on.
25. The role of the sustainability appraisal
is key in informing judgements about trade-offs. It is essential
that the current sustainability appraisal procedures are robust
enough to do this.
26. English Heritage can see benefit in
a 15-year time horizon for land allocation provided that proper
evaluation of the land, including historic landscape characterisation
or other parallel assessment of the land's character before the
decision to allocate it is taken. Such techniques should be included
in "the evidence base for quicker decisions and better outcomes".
27. "The summary of key changes"
does not include any mention of social, environmental and resource
impacts which are mentioned elsewhere in Planning for Housing
Provision. English Heritage believes mention should be made of
these issues as they will play a significant part in determining
where new house-building takes place. Environmental considerations
need to be clearly "factored in".
28. English Heritage supports the proposal
to encourage greater joint working between local authorities to
minimise distortions in the market caused by adjacent authorities
taking different lines on housing development.
29. English Heritage also wishes to restate
the desire to engage at the earliest stages of proposals for development
of housing with local authorities, to help others give the historic
environment due consideration, and help speed appropriate schemes
through the planning process.
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