Heritage Link has submitted a response to the consultation on the draft PPS 15: Planning for the Historic Environment and the draft Practice Guide. The response was informed by member’s feedback gathered during a dedicated PPS15 members’ seminar and through communication on an individual basis.
It supports the overarching objectives of PPS15 to develop planning policy for the historic environment that is clear, up-to-date and which takes an integrated approach to all types of heritage asset. Policies that encourage greater understanding of heritage assets, promotion of pre-application consultation and referral to expert advice are welcomed.
However, Heritage Link has expressed the consensus view of members that the PPS and guidance currently fall short of meeting their stated aims and represent a potential weakening of protection for the historic environment. Key areas for concern outlined in the response include:
- Implementation of terminology and policies based on Bills not yet enacted (Draft Heritage Protection Bill
- and Local Democracy, Economic Development and Construction Bill respectively);
- Narrowing of scope for public inclusion and engagement in the decision-making process in contrast to key principles set
- out in the Heritage White Paper;
- Complete lack of recognition of the historic environment’s contribution to economic, social and environmental benefits;
- Concern at the way climate change mitigation is positioned in relation to the historic environment;
- Possible underestimation of the burden on local authority resources, in relation to HERs, interpretation of new terminology
- and guidance and pre-application consultation;
- Absence of any assessment of the demands made on non-government heritage bodies either national or local – Annex A
- forecasts increased demand for their expertise;
- Omission of any reference to the role of local designation in place-making;
- Lack of sufficient clarity and practical help in the draft Practice Guide.
Heritage Link took the opportunity to urge the Government and English Heritage to implement practical suggestions for amendment put forward in our response and those of individual members. Meanwhile, a proposal was put forward to engage a working group of members in re-drafting the Practice Guide so that both the PPS and guidance might be published concurrently before the next general election.
The Heritage Link response, those of member organisations and others are available to download below:
- The National Trust response
http://www.nationaltrust.org.uk
- Society for the Protection of Ancient Buildings (SPAB) response
http://www.spab.org.uk
- Council for British Archaeology response
http://www.britarch.ac.uk
- Historic Houses Association response
http://www.hha.org.uk
- Historic Towns Forum response
http://www.historictownsforum.org
- IHBC and RTPI joint response
http://www.ihbc.org.uk/ and http://www.rtpi.org.uk
- Joint Committee of the National Amenity Societies response
http://www.jcnas.org.uk/
- Institute for Archaeologists
http://www.archaeologists.net
Other responses
- The Archaeology Forum
- National Historical Ships
- Civic Society Initiative response
www.civicsocietyinitiative.org.uk

