Surveying professional attitudes towards heritage

As part of my PhD research I am currently rolling out a survey designed to be taken by professionals involved in a range of historic environment roles, particularly those who deal with the built heritage, from listed buildings, to historic landscapes, to townscape character.

The survey (which can be found at
http://bit.ly/heritageattitudes
) aims to assess the range of people who are involved in such work as selection, designation and management of heritage assets, the consideration of planning and heritage consents, to those applying for them, advocating new development, responsible for it’s design, and those who are contracted to work on surveying, recording, investigating, repairing – and even demolishing them. But listed buildings processes are only an example: The opinions of anyone whose work affects or is affected by heritage assets is sought.

The underlying purpose is to consider whether these range of professionals have different views on heritage, different perspectives on the regulations that govern practice, and different principles guiding their work.

This hints at one of the main problems with trying to analyse policy making and implementation for its content – How do we know what principles are underpinning the interpretations of the texts of a particular policy? Who is using it, why, and how?

Heritage – as recognised in various government statements – underpins a great deal of what we consider to be the character of places, their historic context, or local distinctivness. Understanding the broad range of technical elements of the planning policy is therefore a prerequisit of much of the work which goes into the process of building a new housing estate, finding a location for a new windfarm, or even replacing a functional infrasctructure feature.

So what do local authority planners know about heritage? What do architects of modern housing, or civil engineers, know about heritage? What do Tescos’ planning team know about heritage? What do they think about sense of place, significance, or even sustainable development? How would these people interpret the demands and principles of policy differently?

We can all read the 3 pages devoted to the subject in the NPPF, but if we are trained differently, how do we know that we are going to act similarly when asked to interpret policy? What happens when there are 1000s of pages of guidance and local regulations, or when technical training supported by particular professional institutes takes years to complete?

These questions have potentially important ramifications in an era where some local authorities are scrapping all archaeological and heritage services in a bit to cut costs, where developers are loath to increase expenditure on heritage related S106 agreements that eat into ever-shrinking profits, and where government regulation and guidance is becoming more and more sparsley detailed. Professional values and the consequent interpretation of policy are thus key to predicting how heritage will survive when regulation is relaxed.

By designing this survey, I hope to be able to plot how heritage values relate to various sectors which deal with historic assets as part of their work. It will, hopefully be able to show if planners think the same as architects, and the same as historians or archaeologists.

The questions on heritage value are designed with reference to various principles of policy that have existed in the past 20 years. They allow a range of opinions to be articulated relating to various aspects of the historic environment.

It also questions whether legislative frameworks are clear, effective, and adequate for the processes they engage in and will provide some idea as to professional attitude towards the political processes within which heritage is embedded.

If you are interested, please take the survey at 
http://bit.ly/heritageattitudes
.

Your reponses will be of great value to my work and your time is most appreciated.

Worrying cuts to York’s Historic Environment Services proposed

Last week I was in the City of York Council’s brand new West Offices building, a tasteful and modern refurbishment of a Grade 2* Listed former railway building. I was pleased by how well the building’s heritage had been treated and modernised. A perfect space for a modern council to administer the business of a historic city.

However, the very same day the news broke that proposals to drastically cut the historic enviornment services for the city’s councils were advancing, which would include the reduction of the City Archaeologist and Landscape Architect’s role from full time to 3 days per week, the reduction in Conservation Officers from 2.5 to just 0.6 and cutting the countryside manger post altogether.

Such a drastic cut is simply has to been seen by the conservation-minded citizen as absolutely outragous attack on this citie’s historic built environment, its heritage, and archaeology. Stinging criticism was quick from all angles of the profession and from the York Press (who’s article can be seen here).

I don’t think it can be stressed enough how much a city like York is built upon its historic environment. If the city has aspitations to continue to be a tourist hot-spot in the north of England, a scenic city which attracts investment and business, and a place where residents are proud to live, it must start by acknowledging and protecting its heritage. It is at the very base of what York is and why it is important. I have no doubt that the vast majority of people will confirm that, when asked. I fear that the Council are being duped by the false assumption that they will be seen as betraying residents if other services, such as education are cut, even if there is more scope to do so. Certainly expecting the already tiny historic environment team to bear a disproportionate share of the cuts is not the answer.

It is a serious worry that this proposal comes with no guidance over what services should be scaled back (or totally lost), no opportunity to justify existing roles before they are cut, and no strategy to deal with the shortfall in services that will be created. The fact is that development which affects archaeology in York requires some expert in the Council to comment on and pass archaeological reports from developers, to assess the quality of the consideration of the impact on heritage assets, and on their surroundings, contained within any proposals. Without adequate provision this simply will not be possible.

The fact is that many archaeological reports are poorly written and do not meet the requirements of the primary legislation or planning policy – it takes significant pushing for them to do their duty by planning policy. Without an expert assessment, it will not be possible to sort those who have carefully followed planning regulation from those who have simply treated the ‘heritage assessment’ part of the application as a burdensome extra to be got out of the way as quickly as possible.

These proposals are perhaps even more worrying for the indication they give as to the state of affairs nationally in the current climate. If a historic city of York’s calibre – a place where you can’t swing a shovel without striking nationally important archaeology - is able to do this, what hope for the archaeology and heritage services in other areas of the country not so famed for its historic architecture, heritage and archaeology? What hope for the Wolverhampton and Cleveland’s of this country – places which have only a fraction of the designated assets York does? York City Council are both embarressing themselves by cutting their heritage provisions below levels of other smaller and historically less significant authorities, and setting a dangerous precident for other historic towns and cities.

It is truly troubleing, also, that Local Authorities feel that meeting offical guidelines of the effective and legally mandated work to protect heritage is not worth following. Be it responding with an expert line on archaeological impact, or providing effective historic environment records.

It must be hoped that York City Council realise the error in judgement of these proposals. I must also be hoped that a great wave of public response makes them rethink, for the effects could be dire, both for York, and as a grim portent for the rest of the country.(Image: Inside the new City Council West Offices – credit: s-harrison.co.uk)

Some half-formed thoughts on potential of Universities to affect change in archaeology.

On Friday I attended a discussion held by Martin Carver at the University of York which was well attended by representatives from across all branches of the profession, from English Heritage to commercial diggers. It’s purpose was to discuss the vacuum of progress the profession is currently in, and to try to come up with a way in which we, as a group, could do something about the way we move forward, using the agenda of the Southport report as a starting block.

The University sector is in a peculiar position regarding post-PPS5 archaeological ethics (as I said in my recent article in the Archaeologist vol.83), as it is at once isolated from the impact zone of the policy, since it is not normally or necessarily a direct part of the planning process, and at the same time, perhaps in the best place to affect change in professional practice on a level which will achieve what Southport had in mind for archaeology.

In the commercial and local government sectors, where hard cuts are biting and staffing levels are at near record lows, it is perhaps understandable that successive rafts new policy cannot generate the excitement and innovation. Both groups are being asked to do more and more with less and less, when it is as much as can be asked to simply get any job done at all.

The argument is that University research which is driving technological advances in practice should be being thought of with an end product – as envisioned by the Southport Group – in mind. If the processes of actually doing archaeology were formed in a way which  were sympathetic to the goals of public engagement and the achievement of new knowledge and understanding then we would have a much better chance of delivering positive change. And whilst not untouched by funding cuts and other pressures, the University research sector does still have energy to use in pursuit of a grander agenda of the level necessary to affect change in the sector.

Professor Mike Fulford of the University of Reading has spoken of the forward thinking partnerships with commercial and local government units for the achievement of better results from commercial projects. The wealth of information dug up in the foundations of new development, previously consigned to inaccessible grey literature is now, with greater frequency, being read and used by students and academics who have the power to innovate to achieve interesting results for expanding our understanding as a profession, and for the wider public as well, if only an outlet into the public domain could be achieved.

That there is positive discussion within universities to actually engage with the wider profession in a way which has so often been lacking is encouraging. By using their privileged position regarding research freedoms, universities can drive Southport’s aims forward, and by reforming some of the ways in which we do archaeology we stand a better chance of actually altering the outputs by having a product that has been designed from the ground up, rather than by trying to re-polish the results of an out-dated system of investigation which has produced an inferior product for years.

This group may offer one of the best hopes for sparking institutional change in the next few years and I am looking forward to the next meeting.

Is now the time for local heritage lists?

With the final NPPF now known and currently being digested by all interested parties, heritage practitioners can begin to think about the opportunities and challenges that lie ahead (without relying on wild speculation about policy constraints).

Historic environment NGOs must not fail to capitalise on the localism agenda’s decentralisation opportunities. In terms of planning, the Localism Act contains many, if not all of the implications of PPS5’s ethos of public engagement and community social value that the NPPF perhaps fails to replicate in full.

The NPPF does, however, set the scene for local plans to do much more for the heritage. It recognises the social value of the historic environment, the important contribution that heritage can make to one’s sense of place and local distinctiveness, and also recognises the intrinsic value of cultural and natural landscapes which people attach community value to.

Within this and with reference to localism’s principles, local authorities and neighbourhood planning groups can take up the chance to comprehensively map their local heritage within their plans.

To do this they have the following tools at their disposals:

1. Local lists
2. Local green space initiatives
3. HERs

1.  Local heritage lists were introduced in 2007 in the Heritage white paper but have never been especially prominent in the raft of heritage protections that have permeated the planning process. The current government’s principles of decentralisation seem to carry the potential to change this as local plans should be better able to protect the heritage that is valued locally.

The NPPF retains roughly the same definition of ‘heritage asset’ we had in PPS5:

 ‘A building, monument, site, place, area or landscape identified as having a degree of significance meriting consideration in planning decisions, because of its heritage interest. Heritage asset includes designated heritage assets and assets identified by the local planning authority (including local listing).’ (appendix 2)

(Missing is the phrase ‘during the process of decision-making’ which is found in PPS5 and the draft NPPF inserted just before the parentheses – It is unclear to me whether this has implications for consideration of local assets which are not designated prior to an application for development, but I suspect that court cases will be brought to decide this in the future).

There are extra protections attached to ‘designated heritage assets’ which are considered to be those assets on national registers, including the statement that;

‘Substantial harm to or loss of designated heritage assets of the highest significance, notably scheduled monuments, protected wreck sites, battlefields, grade I and II* listed buildings, grade I and II* registered parks and gardens, and World Heritage Sites, should be wholly exceptional.’ (para. 128)

This privileges national designations, but despite this the text of the NPPF implies that locally listed heritage assets must be considered when determining planning applications in a manner appropriate to their significance.

However, it is up to local authority or neighbourhood groups to insist that such a list gets written and that it is done so appropriately with adequate community participation, in line with principles of public participation and the community value of heritage as defined in the National Heritage Protection Plan (NHPP), and likely to be echoed within the historic environment guidance that will appear to support the NPPF.

2. Local Green Space initiatives (para. 76-78) are, within the NPPF, a useful concept with which to protect heritage assets such as parks, village greens, playing fields, or other open spaces. Whilst those heritage assets which are not (or are not situated within) green areas will not be eligible for this particular listing, those that are will gain more protection than those on local lists, being ranked alongside nationally designated assets in terms of explicit exemptions from development in all but the most special circumstances (para. 76, 14).

Again however, it is worth noting that Green Spaces can only be designated when the plan is being written or revised, and so planners have to make sure that they allow for adequate community participation in securing designation for all local green spaces that are judged by the community as having sufficient value as to be worthy of protection from future development at the time that they are writing their plans.

3. Historic Environment Records (HERs) are a familiar battleground for heritage NGOs, and will continue to be fought for in the face of tough budget cuts and dwindling employment figures.

However, their place in the NPPF will revitalise them in the fight. It is stated that HERs must be consulted during development applications (para. 128, 141) and that they should be maintained in an appropriate manner so as to keep them relevant and up-to-date.

As important sources of information on significance that already exist in local authority areas, they will be invaluable in the formation of local lists and for speedily obtaining statements of local significance.

The HER also has great potential for public engagement, and if managed with this in mind could provide links between communities and heritage concerns in the planning process: For instance, by making them easily accessible on-line and by making local lists available through them.

As with local listing, it is highly important that heritage NGOs continue to push this message with DCLG and DCMS, or (failing an official government re-statement -which, alas, is unlikely) from English Heritage. Once again, this will likely be strongly asserted in the forthcoming sectoral guidance.

What is of concern is that in the rush to create a local plan before the 12 month NPPF implementation window closes some or all of these heritage concerns may not be given the necessary attention to make sure they are carried out properly, or, without applied pressure from heritage NGOs such as English Heritage and Natural England some LPAs may fail to realise either the benefit of defining a quality local list or the public sentiment in support of protecting local heritage (see the NHPP for statistics)

We must hope that English Heritage are swift in their release of guidance to local planning authorities, and that they are able to assign sufficient resources to supporting LPAs and neighbourhood groups in their drafting processes, and also that the Heritage Alliance’s Historic Environment Forum move to pressure government to officially endorse its Historic Environment guidance soon.

Heritage responses to the NPPF

So the National Planning Policy Framework has been released.

Because there is so much commentary available at the moment (just see Andrew Lainton’s furious posting over the past 24 hours) I’m going to focus my attention on the implications of the document on heritage interests and archaeology.

To start, here are some of the heritage body’s responses:

Council for British Archaeology

Institute for Archaeologists

The Heritage Alliance

Federation of Archaeological Managers and Employers

Rescue

We can see some recurring themes:

• An overall satisfaction: There’s a definite improvement in tone, and this is universally recognised. The mention that heritage assets get in the core principles is a big factor in upping the perceived importance of the historic environment as an integral part of the planning process.
•  Historic Environment Records: A priority concern for heritage bodies currently, and the Framework puts minds at ease by appearing to make it difficult for local authorities to follow through with plans to drop their HERs entirely. However, a restatement of HER principles from DCMS or English Heritage should be pushed for in the following weeks or months is desirable to really hammer home the implication.
• Non-designated assets: Non-designated assets are largely ignored in the final document, which reduces somewhat the standard of protections that existed under PPS5. And whilst the ‘intrinsic value’ of non-designated countryside was recognised in the text, heritage assets or valued places of community value were not explicitly recognised.
• Loss of key heritage objectives: To contribute to ‘knowledge and understanding’ was one of the key principles of PPS5 and retained its place in the historic environment chapter of the draft. It is absent from the final document. This seems a peculiar thing to have lost and potentially highly significant in the light of change working practices that archaeological practitioners have begun to engage with in the last two years (or more). It may change little, but not having the objective explicitly outlined is disappointing.
• Forthcoming Historic Environment practice guidelines: There is now a sense of urgency among historic environment professional bodies to get the government to officially approve a sectoral practice guide that will formally back-up policies in the NPPF. The Historic Environment Forum has a draft, which they are sitting on, waiting for a moment to present it to DCLG and DCMS, and it is important that they keep up pressure in lobbying for this.

Next Steps

Going forward, the main thing is to keep trying to influence the production of local and neighbourhood plans, which will have a significant ability to define particular heritage policies which could more explicitly follow the example set by PPS5. English Heritage will need to take a lead role as statutory advisor to LPAs on heritage matters, and the other historic environment NGOs will also have to ensure that plans for advising and guiding LPAs are in place so that no local or neighbourhood plan is allowed to drop concerns for their heritage. The next 12 months then will be just as critical as the last 12 for the heritage within the planning system.

NPPF: On the outside

Since this will be my last blog before the National planning policy framework is set to be released, I thought I’d reflect on just how little we know going into the publication of the final document that is expected (although by no means guaranteed) on the 21st March.

So, who knows what is going to be in the NPPF when it is released on Wednesday? Well, it’s a short list, that’s for sure. It certainly doesn’t include anyone who the BBC’s Sunday Politics has the power to book. Viewers yesterday were instead treated to the bizarre spectacle of the DCLG spokesperson Stephen Hammond giving assurances on a document he hadn’t even been allowed to read himself (
http://www.bbc.co.uk/news/uk-politics-17421600
).

Conservative MPs don’t make the list either (here). It doesn’t include anyone in the government’s advisory bodies like English Heritage or Natural England, and doesn’t include any other environmental or historic environment NGOs either (here). And it doesn’t include the media, who are revelling in rumours derived from various officials who themselves probably haven’t read the final document either.

The government’s strategy in coping with this abhorrent lack of any tangible information seems to be to assure everyone of everything. The exception is George Osborne, whose strategy seems to be to unilaterally declare anything he wants, in the hope that he’s too important not to have the final say on absolutely everything that government does (
http://www.telegraph.co.uk/earth/hands-off-our-land/9151464/Hands-Off-Our-Land-Frustrated-Osborne-vows-to-make-building-on-countryside-easier-as-cracks-show-in-Government.html
).

How can it be that we are all so on the outside of these reforms? How can it be that the vast majority of expertise relating to heritage, the environment, wildlife, planning and development have been shut out so categorically? How can it be that the government can provide assurances on everything, yet prove nothing, in answer to public scrutiny and media pressure? How can it be that rumour has been the primary source of information in this entire debate?

Conclusions? Whatever happens on Wednesday (and I expect a perfect storm) there have been some serious questions raised about the government’s leadership and handling of the policy drafting process that should not be allowed to be forgotten when we finally see what the new planning system looks like.

The NPPF Rumour Mill

The release of the National Planning Policy Framework is apparently imminent, and the rumour mill is churning! But what exactly ought we to believe?

Newsnight stuck its neck out to say no major changes on Tuesday 6^th, but today (Thursday 8^th) in The Telegraph we heard that brownfield first has been reinstated, the +20% provision for housing has been dropped, we will have increased protection for heritage, and a more balanced definition of sustainable development.

Sceptical as ever, I am unsure exactly what to believe, but if the Telegraph has it correct, then I think it will not look nearly as disappointing as it could have been. Here is a breakdown of what we have been told and what else we need to look out for:

The presumption in favour of sustainable development: This has become the headline fight, but if it is deployed correctly it could be completely workable in a system that fully recognises green belt protections and maintains the ethos of heritage protection that we had in PPS5 – i.e. one that is explicit about the value of cultural and natural heritage assets such as local green spaces.

Brownfield first: This would also be counted as a victory for countryside campaigners. Preventing unnecessary countryside development that would only serve to lower developer costs is a sensible move. However, schemes with truly beneficial potential to stimulate economic grow, such as the example of expanding development at Pinewood studios (as referenced in the Telegraph piece) could still be granted special permission as ‘clearly and demonstrably’ providing good value for the economy and outweighing green belt concerns as an exception, rather than a rule.

Transition period: This is vital for local authorities to be given time to put local plans in place. But 2 years seems like an optimistic target given how much influence the Treasury is being said to be exerting influence over the final form of the document and the vehemence with which it is pushing a quick implementation. However, without enough time, results could be disastrous. Good luck to Eric Pickles in arguing for this down the final stretch.

Ensure heritage protections remain from PPS5: An explicit clause stating the value of heritage assets, both natural and cultural, designated and non-designated, should be included. Consideration of the concept of ‘landscape’ and reference to the commitments to the European Landscape Convention would be an excellent way to do this (as I argue here)  This will also help to inform how one should understand the definition of;

Sustainable Development: Which will require a clearer setting out of how sustainability  balances the environmental and the social with the economic.

Practical, pragmatic, yet protective policy – this is the potential for the NPPF at its release in the next couple of weeks. It is thinking under these banners that will reduce bureaucracy and stimulate economic growth, not thoughtless deregulation.

However, I predict many more rumours to circulate before the final release!

Assessing landscape in the NPPF and European Landscape Convention

In the context of the recent debate over the NPPF I have wondered just how one ought to reconcile the government’s proposed policy emphasis for the spatial planning system with existing (indeed ongoing) commitments to the management of landscapes under the European Landscape convention (ELC).

The ELC is a Council of Europe treaty that was signed in Florence in 2000 and came into force in England in 2007. Most of the principles of the convention are adequately followed by current policy, but the government are still pursuing a strategy for full implementation which is due to be completed in 2013.

The Convention provides a very useful way to holistically describe the relationships that people have with their surroundings and the way meaning is derived from them. From this alone it should be clear how appropriate this vision is to describe the goals of the planning system:

Landscape as defined in the ELC is without doubt one of the most significant terms used to describe the value embodied in the places that we live. It is a significant concept as it incorporates all aspects of the built and natural environment, takes account of the character of an area, its landmarks and its cultural make-up, including the people that live there and their ways of life – however, it is not a static idea, landscapes are constantly evolving, and require management and planning, as well as protection.

However, the use of landscape as a concept employed within the NPPF does little to evoke the same image of the value of existing places and does not successfully describe the government’s commitment to ‘achieve sustainable development based on a balanced and harmonious relationship between the social needs, economic activity and the environment’ (ELC 2000).

It is perhaps because the ELC falls within the legislative portfolio of DEFRA rather than the DCLG (which would perhaps now be a more logical home for it) that the Convention has been all but overlooked throughout the process of drafting and debating the NPPF.

This is a shame, for even as Natural England and English Heritage under DEFRA are pursuing a programme to ensure UK adherence to the philosophy of the ELC and promote it to the public, the National Trust, CPRE and other critics of the NPPF are crying out for just such a commitment from DCLG.

How is it that we should interpret this apparent lack of coherence between government departments in respect to two apparently different ethical approaches to the management of landscapes? Can critics of the NPPF’s perceived unbalance in favour of developers take comfort in the government’s position on the ELC and its continued role in protecting landscapes through intelligent and balanced management, or must we assume that the ELC will be buried beneath the current drive for economic recovery and development efficiency despite costs to the cultural and natural environments?

Natural England (the main partner NGO assisting with the implementation of the ELC) did raise concerns over the lack of an adequate linking of definitions and emphases between the NPPF and ELC in its very low profile consultation response (available here), however with little or no media attention on the European legislative commitments of government, it seems that this is not an area that will receive any great attention until after the publication of the final text of the NPPF in March.

The war over planning reform

One of the most distressing terms to any political pragmatist must surely be ‘u-turn’; a u-turn is what any politician, party, or government do when they change their stances or opinions, or alter policies – at all, seemingly. The media love u-turns because they are able to paint the turner as being spineless and lacking in faith in their values – and we all hate that, apparently.

The trouble with u-turns is that the label is equally applied to situations in which reasoned debate leads to valid criticism and in turn to sensible policy alteration. Compromise – the holy grail of representative democracy – is thus imagined as a bad thing, and common sense is sacrificed for an image of strength and courage in one’s convictions, even if one’s convictions are half-cocked, un-thought out, or just plain dumb. But when a debate escalates into a conflict, politicians’ fear of u-turns deepens.

In the NPPF debate this is becoming a clear problem. The National Trust, CPRE and the Telegraph (notably) are committed to a hardcore assault on some relatively minor issues in the policy – implied in the language, rather than entrenched in the philosophy. The Tory leadership, meanwhile, are stuck to their guns claiming that the allegations are all false and that the NPPF is vital to the nation’s economic recovery, etc,

Somewhere in the maelstrom, the expert advice provided by the professional organisations (IfA, IHBC, RTPI, CBA, etc.) in the consultation is lost. Practitioners are forced to get behind the overblown media campaign of the NT and CPRE, and hope that they do a good job of defending the sector’s interests, or support the government’s original stance. Mainly, however, they just talk quietly amongst themselves at the sidelines of the debate.

The professional consultations were reasonably positive about the direction of the NPPF, pointing out a handful of reasonable points at which textual clarification would lead to a more seamless implementation and better protections from legal challenges – overall, not a great deal that would have been outrageously contentious. The DCLG select committee report, recognising most (if not all) of these concerns, was pragmatic and well reasoned.

But the NT campaign breeds responses like this from Tory MP Stewart Jackson (
http://conservativehome.blogs.com/platform/2012/01/stewart-jackson-mp-the-national-planning-policy-framework-is-an-integral-part-of-this-governments-gr.html
) and the subsequent NT response (
http://ntplanning.wordpress.com/2012/01/12/sticks-and-stones/
) shows how clearly adversarial the campaign is. The reasoned alterations proffered by a professional sector largely positive about the reforms are ignored in favour of a two-sided war of convictions, and the more that the Telegraph shout and scream, the more hardened against ‘u-turns’ the government will become.

Professional practitioners should be sceptical of the scale and ferocity of media furore surrounding the NPPF, to say the least. I’d call it downright damaging to the chances of seeing a positive policy emerge in the spring.

Communities and Local Government Committee report on the NPPF

The National Planning Policy Framework is in the news again today as the CLG Select Committee published its report on the policy, siding with the National Trust, CPRE, IfA and CBA in criticising its ‘confusing’ ‘vague’ ‘unbalanced’ and ‘unsustainable’ language and concluding that a re-wording of the presumption in favour of sustainable development should be enacted.

The report, however, is actually reasonably positive about the direction being taken, and – call me naive – seems as though it might have struck a sensible balance that means that Greg Clark and the Government will be able to institute a re-write of some of the more contentious issues of the policy without looking like they’ve suffered any kind of serious defeat – which as we all know is the bottom line of politics, rather than, say, real progress arrived at as a result of sensible debate.

Some of the key recommendations are:

1) That the Government remove the ‘default yes’ to development position.

2) The phrase ‘significantly and demonstrably’ should be removed from the passage considering whether the adverse affects of development outweigh the benefits.

3) The emphasis on the commercial viability for developers should be dropped.

4) The phrase ‘sustainable development’ should be more rigorously and consistently defined and should place a balanced emphasis upon social, environment and economic aspects.

5) The ‘presumption in favour of sustainable development’ should exist within the context of local plans, rather than as a decision-making mechanism in and of itself.

Another point made by the Committee was the need for a clearer timetable for the transition, outlining requirements for the positioning of local plans in order to ensure complicity to the policy across the country with no shortfall in capability to implement it when the time comes.

Additionally, I would argue that more detail about what kinds of practice guides can be expected in the future, and elaboration on how aspects of local and national guidance will coalesce may help to ease the passage, at this stage, of a second draft which corrects the most significant issues of the policy.

Perhaps a remaining question is whether there will be a second opportunity to provide feedback on any major revisions to the document that take place over the next couple of months, or whether the government will fear pushing back the assent of the policy further and further into 2012.