Planning for the Historic Environment, England: New Government Planning Policy Guidance
Jonathan Lovie writes:
The Government has, in the past few days, finally launched the long-awaited consultation on a replacement for Planning Policy Guidance Note 15 (PPG 15): Planning and the Historic Environment, which was issued in 1994, and PPG 16 which dealt with archaeology in relation to the planning system.
PPG 15 in particular has been crucial in ensuring that designed landscapes have been given due weight within the planning system. It is this document which states that the impact of proposed development on registered parks and gardens and their settings is a ‘material consideration’ in the determination of a planning application, and that directs planning authorities to include policies for the protection of registered sites and their settings from harmful development in local and regional plans.
This document has served us well, and we shall be scrutinising the draft Planning Policy Statement 15 (PPS 15) with great care to make sure that no dilution of policy with regard to designed landscapes is being proposed.
We shall be making our full response to Government in October, but our preliminary impressions of the new PPS are broadly favourable. While the new PPS is not perhaps worded with the clarity of the former guidance, it appears to be positive in setting out to treat all ‘heritage assets’ on an equal footing. This may be beneficial for safeguarding historic designed landscapes (both registered and un-registered) within the planning process. The recognition, both in the PPS and in the accompanying English Heritage Practice Guide that not all ‘heritage assets’ are known, and that the Register in particular is an incomplete designation, is very welcome.
The PPS follows the lead set by earlier Planning Policy Statements in promoting pre-application consultations, and also re-enforces the role of statutory consultees and other national and local amenity societies within the process. This clearly helps to bolster our role, and that of bodies such as county gardens trusts, in providing expert advice to planning authorities.
While we welcome the strong commitment made to the conservation of Grade I & II* registered parks and gardens, along with other highly graded buildings, scheduled archaeology, protected wreck sites and registered battlefields, we are concerned that this emphasis may leave the 60% of Grade II registered landscapes more vulnerable to development pressure than in the past.
The PPS addresses World Heritage Sites and conservation areas, and in a welcome move states unambiguously that those elements of a World Heritage Site or conservation area which contribute to the significance of the site or area as a whole should be treated as ‘designated assets’ whether they are in fact the subject of national designation or not. This means, for example, that an unregistered area of designed landscape within a conservation area or World Heritage Site which contributes to the special interest of that place will in future have to be treated by the planning authority as if it was registered.
The Conservation Committee will be formulating its response to the draft PPS and the draft English Heritage Practice Guide over the summer, and would welcome any comments from members of the Society.
The documents can be found at: