Newsletter 4th Quarter 2009
Important Changes to Planning Guidance


Draft Planning Policy Statement (PPS) 15: Planning for the Historic Environment

The publication of this Newsletter has been delayed in order to carry news on the progress of the Government’s proposed replacement of its existing Planning Policy Guidance notes on built heritage and archaeology (PPG 15 and PPG 16, introduced in 1990 and 1994). The Draft PPS 15 appeared without warning during the summer holidays and consultation on it closed on 30th October. If adopted, it will become national policy which all local councils must follow when making decisions on individual planning applications.

The new policy says that local authorities should allow the demolition or alteration of historic buildings where the ‘material harm’ caused to an area’s heritage ‘is outweighed by the wider social, economic and environmental benefits of the proposed development’. The policy says that this ‘is likely to benefit developers... for example, it should reduce the number of applications for planning permission, listed building consent and conservation area consent being rejected on heritage-related grounds’. The proposed policy says that ‘material loss of grade 1 and 2-star listed buildings’ should be ‘wholly exceptional’, but it makes no mention of what degree of social, economic and environmental benefit would be required to justify the loss of grade 2 listed buildings (which make up 92 percent of England’s listed buildings), buildings in conservation areas or locally listed buildings.

The emergence of the PPS had done severe damage to the credibility of English Heritage, who have been obliged to back the Government’s approach or risk further cuts to their funding. EH have thus welcomed its launch, seeing it as ‘a very positive development in the management of the historic environment’. They ‘strongly support the principles contained in the PPS’ and argue that it represents ‘a modernisation that brings heritage planning guidance in line with wider changes to planning legislation and English Heritage's own best-practice. We are confident that there is no loss of protection for the heritage.’ (see full text)

Despite such assurances, the Draft PPS has been roundly condemned by those in the heritage lobby with whom this Society has been in touch during the consultation process, including the following:

The vitriol has not been limited to ‘the usual suspects’ in the heritage lobby either. The PPS has been subject to an unprecedented attack by the professional institute of town planners, the RTPI, which normally responds in cautious and technical terms to government consultations. It has launched a scathing attack on PPS 15, saying it has ‘serious concerns’ and demanding ‘significant and substantial changes’. They have condemned it as ‘fundamentally flawed’ and ‘unfit for purpose’. Martin Willey, the RTPI’s President, said: ‘This could prove to be a charter for people who want to knock buildings down. This new guidance assumes that heritage stands in the way of development and economic recovery, which is patently untrue. Historic buildings and places are an asset, not a burden.’ The President of the Royal Institute of British Architects (RIBA), Ruth Reed, said the new policy would ‘cause more problems than it solves’, estimating that ‘tens of thousands of listed and heritage properties could be lost if the PPS is adopted (as it stands)’ (see response). We have asked Tony Baldry MP to take the matter up with the Shadow Ministers for planning and culture.

The Government will publish the consultation responses at the end of January. See this Society’s own detailed response to the Draft PPS.