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:
- Local lists
- Local green space initiatives
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.