Revisions to the NPPF (National Planning Policy Framework) are currently being consulted on and Rescue is extremely concerned to report that we believe, if enacted, these revisions will leave the system no longer fit for purpose as an effective tool for the sensitive and sustainable management of our heritage resources. These revisions offered an opportunity to address genuine issues with NPPF which David Cameron’s coalition introduced as part of a “bonfire” of quangos and legislation, designed to make the planning system simpler. The current Government is pursuing a policy of deliberate arson – removing heritage protection principles a piece at a time through selective burning. The changes from the previous version are on the surface minor, but we feel we’ve passed the line in the sand and the time when we would “welcome” these consultations in our responses has long gone. There’s far too much in the NPPF proposals that diminishes protection systems for Rescue to acquiesce to this.
RESCUE set out a framework for how an effective historic environment protection system ought to function in Rescue Archaeology, Foundations for the Future (RAFFF) in 2015. The NPPF isn’t a heritage protection regime in its own right, but primary planning legislation and guidance is a huge part of such a regime, and as it stands this proposed revised NPPF has failed to take any of the more obvious opportunities to strengthen the system. The biased and damaging presumption in favour of so-called “sustainable” development remains; while the inadequate framework which does not specify qualified and professional assessment or statutory provisions for advisory services and/or HERs persists. The commitment to a proportionality of detail in assessment of heritage assets is fine, but without explanation it falls to non-statutory, sometimes non-existent, local authority services to determine what is and isn’t “proportionate” and in many cases the applicant will decide – an unacceptable situation in a balanced management regimen. An opportunity to introduce the concept of impartiality or at least some measure of trustworthy professional accreditation into the system has been missed, as has the growing need for a firm statement and a policy/legislative commitment to do something about the current lack of permission needed for demolition of any structure that is not a designated asset or one within a conservation area. This latter point is worth stressing, as there are huge numbers of undesignated heritage assets – buildings and archaeology – that are at risk of being demolished without prior appraisal through this ludicrous and easily rectifiable situation. Demolition should require planning consent – is it that hard to countenance?! The “heritage thread” that Rescue highlighted as being necessary across legislative systems was already weak in the NPPF, but has been further weakened by the removal of references to the historic environment from paragraphs 9, 157, 169 and 170, and far from being strengthened, the position of HERs – one which the Government clearly knows the opinion of the heritage sector on – has been additionally weakened by their redefinition from “services” to “resources” (i.e. from an active provision of expert advice and information, to an inanimate “thing”). As before, there is no mention of the need for local authorities to maintain access to qualified impartial heritage and/or conservation advice to assess applications against. In any case, recent changes to planning legislation with regard to brownfield registers and permission-in-principle mean that heritage assets can be legitimately earmarked for development without any prior assessment of their significance and furthermore then destroyed without proposals being in place through the exercise of the unacceptable demolition rules as highlighted above. Two particularly important principles – that regarding the importance of undesignated archaeological sites of national importance, and deposition of archives with museums and the Historic Environment Record (HER) – are relegated to footnotes; this is equally unacceptable and is a positive slap in the face for any sort of influence the heritage sector might have thought we were exerting in the last few years. Pretty much anything that the Vaizey-commissioned 2014 report on Local Government Archaeological Services recommended has been discarded. Coupled with recent and proposed changes and cuts at both Historic England and English Heritage, Rescue can truly envisage nothing but a bleak future for heritage protection in this country unless the current trends are reversed.