Communities and Local Government CommitteeWritten evidence from the Heritage Alliance
The Heritage Alliance
The Heritage Alliance is the largest coalition of non-government heritage interests in England. Together its members own, manage and care for the vast majority of England’s heritage. Our heritage plays an outstanding role in our national culture for residents and visitors alike; it is a powerful force that brings multiple benefits to individuals and communities.
Established in 2002 by the voluntary heritage groups themselves, the Alliance brings together 91 major organisations from specialist advisers, practitioners and managers, volunteers and owners, to national funding bodies and organisations leading regeneration and access projects. Their specialist knowledge and expertise across a huge range of issues - including planning matters and asset transfer - is a highly valuable national resource much of which is contributed on a voluntary basis for public benefit. They are supported in turn by thousands of local groups and around five million members, with a huge volunteer input of over 450,000 a year.
This evidence has been prepared following a meeting of the Alliance’s Spatial Planning Advocacy Group, which brings together Alliance members with particular planning expertise to establish our policy positions on specialist issues such as this.
Summary
The Alliance supports the principle of simplifying planning guidance.
The Alliance supports many of the policies in the Historic Environment chapter.
But
The Alliance has strong concerns about the operation of the overriding presumption of sustainable development and the default answer to development being “yes”, which appears to trump historic environment protection
The historic environment is not properly recognised as a major driver for economic change and regeneration
The Alliance notes the weak protection for developments where less than “substantial harm” may be caused to historic buildings
There should be a presumption in favour of developing brownfield sites first.
The Draft National Planning Policy Framework
The Alliance welcomes the National Planning Policy Framework’s (NPPF) basic premise of simplifying planning policy, which has proliferated over the years to a large number of complex documents. We are pleased to see the prominence given to heritage in the NPPF with mentions in the ministerial foreword and the introduction, particularly paragraph 2 as we believe our heritage is a national asset, bringing economic, social and environment benefits. Its long-term future is best protected through the planning system since once destroyed, it is gone for ever.
The Historic Environment chapter (pp 50–52) has broad support among Alliance members, with some caveats where developments might cause less than substantial harm to the historic environment.
However, the Historic Environment chapter is subordinate to the NPPF as a whole—in particular the presumption in favour of sustainable development—will mean that adverse impacts of a development on the historic environment can be overridden by the wider government policy objectives for economic growth. The Alliance fully recognises and supports the need for sustainable development, and we believe that a properly balanced approach to sustainable development is consistent with protection of the historic environment. But we are concerned that the considerable weight applied to the economic and growth component will lead to development of mediocre quality with adverse effects on our heritage and the wider environment.
The Questions
Our responses to the questions asked in the committee briefing are as follows:
Does the NPPF give sufficient guidance to local planning authorities, the Planning Inspectorate and others, including investors and developers, while at the same time giving local communities sufficient power over planning decisions?
The NPPF will require supplementary practice guidance in a number of areas of the historic environment, on determining significance and value, on proposals which will cause less than substantial harm (paragraph 183).
Guidance will be required on other areas, in particular in the case of marketing of a heritage asset to demonstrate lack of viability and the enabling development policy.
Without these clarifications, and greater clarity of language throughout, the NPPF may lead to less certainty and confidence in the planning system, not more. Further clarification will benefit all users of the system.
The status of supplementary practice guidance is as yet unknown, but would be critical to the efficient operation of the planning system. It should be recognised as a material consideration.
Is the definition of “sustainable development” contained in the document appropriate; and is the presumption in favour of sustainable development a balanced and workable approach?
The broad definition of sustainable development is appropriate (paragraph 9), as it mirrors the Brundtland principles which have general acceptance. However, the UK Government’s 2005 sustainable development strategy includes a helpful set of guiding principles which should be used in the NPPF to ensure that the policy translates into practice.
Our members believe the presumption in favour of sustainable development is weighted excessively in favour of the economic component of sustainable development to the detriment of social and environment components. The historic environment is not a barrier to economic progress, indeed it has the capacity to be a major driver for economic change and regeneration notably its essential underpinning to the tourism industry.
The value of heritage to the wider economy does not come through the text of the draft NPPF at present and we suggest that an introductory paragraph to the Historic Environment chapter might outline how our heritage contributes to sustainable development, outlining its economic and other values including the importance of re-use in the context of energy efficiency. Other chapters in the NPPF would benefit from similar treatment.
Paragraph 14 states (inter alia) that Local Plans should have flexibility to respond to economic changes and that Local Planning Authorities should grant permission where plans are absent, silent, indeterminate or where relevant policies are out of date. It goes on to say that these policies should “apply unless the adverse impacts of allowing development would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole”.
This test of development only being refused where the adverse impacts would significantly and demonstrably outweigh benefits is a high one, and poses a considerable risk to the historic environment. The balance of harm to the environment against the benefit of the development is heavily weighted in favour of development.
Are the “core planning principles” clearly and appropriately expressed?
We have responded to the principles expressed in paragraph 19 where they apply to the historic environment.
Planning should be genuinely plan-led, with succinct Local Plans setting out a positive long-term vision for an area. These plans should be kept up to date and should provide a practical framework within which decisions on planning applications can be made with a high degree of certainty and efficiency.
That the system is plan-led is accepted, but few local authorities have adopted local plans at present. This will put considerable pressure on them to prepare them. The requirement to keep plans up to date will depend on the resources available to local authorities and our concern here is further compounded by the loss of specialist conservation and archaeological expertise in Local Authorities which may exacerbate the shortfall.
Planning should proactively drive and support the development that this country needs. Every effort should be made to identify and meet the housing, business, and other development needs of an area, and respond positively to wider opportunities for growth. Decision-takers at every level should assume that the default answer to development proposals is “yes”, except where this would compromise the key sustainable development principles set out in this Framework
The purpose of planning is wider than purely economic goals. The role of the planning system is to balance economic development with the wider social, cultural and environmental needs. The default answer being “yes”, will mean it is difficult to refuse consent, to negotiate improvements in detail and design, and to impose conditions to achieve the same.
This is our most serious concern.
Planning policies and decisions should take into account local circumstances and market signals such as land prices, commercial rents and housing affordability. Plans should set out a clear strategy for allocating sufficient land which is suitable for development in their area, taking account of the needs of the residential and business community
Market signals may be temporary and transitory. The value of a truly plan-led system is to facilitate the longer-term view, framing the management of development and avoiding potentially harmful decisions taken, based on short-term fluctuations in the market.
In considering the future use of land, planning policies and decisions should take account of its environmental quality or potential quality regardless of its previous or existing use
The term environmental quality needs to be better defined. The Alliance strongly supports an approach which means developing brownfield land first, and one that recognises the value and amenity of the historic and natural environment, both designated and undesignated.
Planning policies and decisions should seek to protect and enhance environmental and heritage assets in a manner appropriate to their significance, and reduce pollution. Where practical and consistent with other objectives, allocations of land for development should prefer land of lesser environmental value.
The Alliance supports this core principle, subject to appropriate definition of land of lesser environmental value.
Planning policies and decisions should make effective use of land, promote mixed use developments that create more vibrant places, and encourage multiple benefits from the use of land in urban and rural areas, recognising that some open land can perform many functions (such as for wildlife, recreation, flood risk mitigation, carbon storage, or food production).
The Alliance supports mixed use developments for rural and urban contexts. Urban heritage is usually found to have mixed uses, supporting sustainable local economies.
Planning policies and decisions should enable the reuse of existing resources, such as through the conversion of existing buildings, and encourage, rather than restrict, the use of renewable resources (for example, by the development of renewable energy).
The Alliance and its members actively support the re-use of existing buildings. The existing building stock has much to offer in the process of sustainable development, meeting social needs by regenerating places which people value, meeting economic needs by avoiding comprehensive redevelopment, and meeting environmental needs by reducing the loss of embodied energy.
Planning policies and decisions should actively manage patterns of growth to make the fullest use of public transport, walking and cycling, and focus significant development in locations which are or can be made sustainable.
The Alliance supports measures to improve provision of public transport and cycling as an alternative to car use. Many older areas are themselves the products of a low carbon economy, providing examples of more sustainable patterns of living.
Planning policies and decisions should take account of and support local strategies to improve health and wellbeing for all.
The Alliance supports this principle. Our heritage is highly valued for its own sake by people across all parts of society so much so that it is integral to our quality of life.
Planning policies and decisions should always seek to secure a good standard of amenity for existing and future occupants of land and buildings.
The historic environment contributes to good standards of amenity for occupants of buildings as well as the wider public amenity value afforded to many others through much-loved landscapes and streetscapes, now and in the future. Good policies for managing changes to heritage assets will allow them to continue to do this.
Is the relationship between the NPPF and other national statements of planning-related policy sufficiently clear? Does the NPPF serve to integrate national planning policy across Government Departments?
We would welcome clarification of the relationship between the NPPF and National Planning Statements. We believe that there would be value in Government producing a national spatial plan.
Does the NPPF, together with the “duty to cooperate”, provide a sufficient basis for larger-than-local strategic planning?
The duty to cooperate is key to ensuring that economic and development objectives are met in the most appropriate manner. Alliance members are concerned that the duty to co-operate is not an adequate replacement for the loss of regional spatial strategies and co-ordinated green belt policies where a number of local authorities are involved.
September 2011