The government’s long awaited National Planning Policy Framework was released recently, and the initial Twittersphere reaction in general seems to be “not as bad as we feared. Not as good as we’d like.”

Now, here at Heritage Action we’re just ‘ordinary people caring for extraordinary places‘, and don’t pretend to be experts in planning legislation or government policy or the ins and outs of party politics, so what’s our ‘ordinary people’ take on the document which can be downloaded here?

Well, at first view, it consists of a 72 page Framework document, with a further 27 page Technical Guidance document. A lot of reading after a hard day’s work! But looking again at Twitter, a lot of quotes are appearing there of specific articles of the policy. Some of these caught our eye, and raise some uncomfortable questions. Of course, from our own perspective although we recognise the need for development and growth, we do not see this meaning that heritage is suddenly more expendable than it used to be, whether it be in the form of ancient monuments and sites of prehistoric activity, later sites of historic interest such as battlefields, or the historic/industrial built environment. The buzzword seems to be ‘sustainability’ and that ought to mean conservation is always something to be given real weight not a token mention.

At this point, it’s worth quoting para 7 from the framework, regarding sustainability:

7. There are three dimensions to sustainable development: economic, social and environmental. These dimensions give rise to the need for the planning system to perform a number of roles:
● an economic role – contributing to seems to be  building a strong, responsive and competitive economy, by ensuring that sufficient land of the right type is available in the right places and at the right time to support growth and innovation; and by identifying and coordinating development requirements, including the provbe given ision of infrastructure;
● a social role – supporting strong, vibrant and healthy communities, by providing the supply of housing required to meet the needs of present and future generations; and by creating a high quality built environment, with accessible local services that reflect the community’s needs and support its health, social and cultural well-being; and
● an environmental role – contributing to protecting and enhancing our natural, built and historic environment; and, as part of this, helping to improve biodiversity, use natural resources prudently, minimise waste and pollution, and mitigate and adapt to climate change including moving to a low carbon economy

We note here that the historic environment (which we would hope also includes the prehistoric environment!) is lumped in with the ‘environmental’ role. It’s our view that the historic environment performs a greater ‘social’ role than an environmental one, but maybe we’re knitpicking, as para 8 states that “these roles should not be undertaken in isolation, because they are mutually dependent.”

Much has been made in the lead-up to the document’s release of the phrase ‘presumption in favour of sustainable development‘, which is at the heart of the document, and is frankly, the most worrying aspect of the whole thing, particularly in association with the localism focus, whereby Local Councils would seem to have almost (there are exceptions) carte blanche to rubberstamp development proposals which fit with their ‘Local Plan’.

Given the recent stories in the Press of payments for audiences with the Prime Minister and other cabinet members, there’s no reason to suspect that similar ‘arrangements’ do not occur at the local level, so that a developer for instance, could bump into a local councillor (and many councillors are developers, don’t forget) on the golf course or at a charity dinner and arrange to get the nod on a particular plan, for favours. The Old School Tie, a nod and a wink, say no more!

Another quote to illustrate this concern, from para 17:

planning should be genuinely plan-led, empowering local people to shape their surroundings, with succinct local and neighbourhood plans setting out a positive vision for the future of the area.

Sorry, but in our view that opens the gates for all kinds of potential deals to be struck. It may be simplistic, but in many cases, particularly where nationally important sites are concerned, the decision is too important to be left to those closest to the case. Imagine if you will, that you’ve been arrested and taken to court for a charge, say theft, or possibly even assault or murder! Would you want the jury to be composed of people who knew the victim, or people who were impartial and could look at the facts without prejudice?

Now that same para (17) also states:

(planning should) conserve heritage assets in a manner appropriate to their significance, so that they can be enjoyed for their contribution to the quality of life of this and future generations

and again we would ask, who determines that significance? What balances and checks will be in place to ensure that ‘interested parties’ cannot sway decisions ‘in favour of sustainable development’ by downplaying the significance of a site?

Jumping ahead, and ignoring for now the sections on town planning and transport infrastructure (but remembering the Rotherwas Ribbon and Mynydd y Betws debacles), in the section on ‘Conserving and enhancing the natural environment’ we find, in paras 112, 115 and 116:

112. Local planning authorities should take into account the economic and other benefits of the best and most versatile agricultural land. Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality.
…
115. Great weight should be given to conserving landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to landscape and scenic beauty.
116. Planning permission should be refused for major developments in these designated areas except in exceptional circumstances and where it can be demonstrated they are in the public interest.

We would ask specifically here, what of the heathland, moors and woodlands outside of National Parks, AONBs etc? Are they to be sacrificed to the great god Mammon? After all, agriculturally, they can be considered to be (para 112) ‘poorer quality land’, can they not?

Finally on page 30, (just a few pages before the 30+ pages of Annexes and Appendices start) we come to the section on ‘Conserving and enhancing the historic environment’, the section of most interest to us here. Para 126:

126. Local planning authorities should set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats. In doing so, they should recognise that heritage assets are an irreplaceable resource and conserve them in a manner appropriate to their significance. In developing this strategy, local planning authorities should take into account:
● the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation;
● the wider social, cultural, economic and environmental benefits that conservation of the historic environment can bring;
● the desirability of new development making a positive contribution to local character and distinctiveness; and
● opportunities to draw on the contribution made by the historic environment to the character of a place.

Let’s just take a look at this a little more closely in case you missed it. “Conserve them in a manner appropriate to their significance” – Again, that question of who determines the significance? “putting them to viable uses consistent with their conservation” – what viable uses other than non-income generating tourism or sheep grazing could a site such as e.g Stanton Drew be put to? Well, in answer to that first question, para 128 provides the answer:

128. In determining applications, local planning authorities should require an applicant to describe the significance of any heritage assets affected, including any contribution made by their setting.

Ah, so the person most likely to profit from the development (ie the developer applicant) is the one who decides how significant they feel the site is, from the viewpoint of heritage and setting! How fortunate for the premise of a ‘presumption in favour of sustainable development’ Luckily, this is somewhat mitigated by paras 129 and 130, but we wonder to what level this will be followed, and again, the spectre of ‘local interest’ versus a wider regional or national interest comes into play:

129. Local planning authorities should identify and assess the particular significance of any heritage asset that may be affected by a proposal (including by development affecting the setting of a heritage asset) taking account of the available evidence and any necessary expertise.

130. Where there is evidence of deliberate neglect of or damage to a heritage asset the deteriorated state of the heritage asset should not be taken into account in any decision.

Some possible hope for the Priddy Circles then, in that last para?

There is a lot more of the same (219 paragraphs in total, plus the Glossary and Annexes), much of which need not concern us directly, and other professional heritage commentators have dissected the documents in much more detail and with more insight than we could hope to achieve here – a Twitter search for the hashtag #NPPF will provide a plethora of links to such commentaries. We leave it up to the reader to review the documents for themselves and come to their own conclusion as to whether this Framework will be good for heritage sites or not. Our view? We would have to agree with the closing statement in RESCUE’s response:

“The usual protocol upon publication of such documents is to give a cautious welcome to the new policy provisions and look forward to implementing their provisions effectively in the future. Sadly, RESCUE is unable to commit to either of these protocols in this instance. The publication of the NPPF seems likely to signal the start of a new round of debate and argument over the value we place on our heritage and its role in the rejuvenation of the national economy”