Localism Bill

Memorandum submitted by Save Britain’s Heritage (L 101)

INTRODUCTION

1.  SAVE Britain's Heritage is a registered charity. It was founded in 1975, European Architectural Heritage Year, to campaign publicly for the protection of threatened historic buildings and areas. It carries out its work through press releases, exhibitions and reports. SAVE has been at the forefront of the conservation movement in the UK, pushing for changes in legislation and in government policy to give greater protection to our built heritage, and in raising awareness amongst politicians, professionals and the public about the vital contribution made by historic places and spaces to quality of life and the wider economy.

2. SAVE has always worked closely with community groups and local people fighting to prevent unsympathetic changes to their built environment. Indeed SAVE is only effective when operating in partnership with, and with the support of, local people. Many of SAVE’s recent battles have involved terraced housing in the north of England earmarked for demolition under the Housing Market Renewal (Pathfinder) programme. In 2008 SAVE supported residents in the Toxteth Street area of East Manchester at CPO Inquiry and more recently, SAVE has been fighting with the Saltwell and Bensham Residents Association in Gateshead, to prevent the destruction of hundreds of homes in that area. In Lancaster SAVE, together with English Heritage, attended a Public Inquiry over proposals to redevelop the Canal Corridor area of the City. SAVE worked closely with local group It’s our City to show that the scheme would result in unacceptable damage to the historic environment. The Inspector ruled against the scheme.

LOCALISM BILL

4. SAVE welcomes the core principles of the Localism Bill with its aim of empowering communities to take a greater role in shaping their local environment. We support those elements of the Bill which aim to strengthen the enforcement rules and widen the scope of how the community infrastructure levy to allow it to be used on ongoing infrastructure as well as capital costs.

5. However, SAVE has a number of concerns over the way in which the Bill could impact in a negative way on the historic environment. Our broad concern is that the Bill in its present form would result in a weakening of heritage protection. Heritage assets are, of course, of more than local interest as they are all, to a greater or lesser extent, enjoyed by visitors as well as local people.

6. Looking at the draft Bill in more detail our other concerns relate to:

a) The amendment of Sections 66 and 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990 by Schedule 12 of (para 23) of the draft Bill. This would lift longstanding and vital protection for the setting of listed buildings and the special qualities of conservation areas by removing the statutory requirement to consider preserve listed buildings and preserve or enhance the character and appearance of conservation areas when drawing up Neighbourhood Development Orders (NDOs).

b) We have serious concerns about the practicality of drawing up Neigbourhood Development Plans which genuinely reflect the views of local people. With the minimum number of people required to set up a Neighbourhood Forum set at three (either local people or those who want to live locally) SAVE is concerned that these Forums could be manipulated by narrow interest groups in a way that could result in development which damages heritage assets as they are at present.

We feel strongly that unless the process is seen as genuinely inclusive, and that there are mechanisms both to provide expert and balanced planning and conservation advice to these Forums and to monitor them to ensure fairness, it will result in a breakdown of trust and cause communities to fragment rather than become more cohesive. Although decisions should be made locally it is crucial that the National Amenity Societies with specific and valuable expertise should continue to be consulted on planning matters.

We are also concerned that economic incentives for new development could lead to Forums being unduly influenced by developers or those individuals seeking to profit from new development. It is, therefore, all the more important that there is a requirement to consider national planning policy guidelines set out in the Planning Act and, specifically, PPS5.

Finally, we are concerned that the system would be open to manipulation by Local Authorities wishing to pursue specific planning strategies which may not have local support. SAVE has direct experience of this in relation to Pathfinder, where unaccountable Steering Groups dominated by council officers, were set up to give the outward impression that council was consulting local people, but pushing one particular development option (in this case demolition and redevelopment).

February 2011