Prehistoric Society Response to the Government S Draft National Planning Policy Framework

Prehistoric Society response to the Government’s draft National Planning Policy Framework

On the 25th July 2011 tThe Government has released a draft version of the proposed National Planning Policy Framework (NPPF 2011) for England for consultation. The Prehistoric Society certainly supports the Government’s objectives “[that] that “...[that]the historic environment and its heritage assets should be conserved and enjoyed for the quality of life they bring to this and future generations” (NPPF 2011, 50, section 176); and also “[to]to “...[to] contribute to our knowledge and understanding of our past by capturing evidence from the historic environment and making this publicly available, particularly where a heritage asset is to be lost” (ibid., section 177). These are laudable aspirations with considerable resonances with the Prehistoric Society’s own aims to promote prehistoric research and facilitate access to the results of this research. The aim to simplify a complex and cumbersome planning legislation and guidance is also welcomed.

There are certain features of the proposals, however, that cause concern. The Prehistoric Society feels that in contrast with the existing PPS5, in the National Planning Policy Framework there has been a switch in emphasis from guiding responsible development to promoting development, without necessarily putting in place clear regulatory safeguards for the historic environment. The NPPF states that “In weighing applications that affect directly or indirectly non designated heritage assets, a balanced judgement will be required having regard to the presumption in favour of sustainable development, the scale of any harm or loss and the significance of the heritage asset” (NPPF 2011, 61, section 185). This apparent notion that the onus must always be in favour of ‘sustainable development’ (however that may be defined)could potentially cause confusion and reductions in the level of protection afforded to the historic environment, without adequate assessments and safeguards.

The Prehistoric Society is also worried gravely concerned that many proposals in the National Planning Policy Framework only consider the impacts of development upon designated heritage assets such as Scheduled Monuments, Historic Battlefields, Grade I and II* Listed Buildings, Registered Parks and Gardens and World Heritage sites (NPPF 2011, 61, section 185). Although iIAlthough it does states that “...non-designated heritage assets of archaeological interest that are demonstrably of equivalent significance to Scheduled Monuments, should be considered subject to the policies for designated heritage assets” ”(NPPF 2011, 61, section 189), but the application in practice of such vague guidelines may cause considerable confusion and might lead to a focus mainly on designated assets. This appears to discriminate against below ground archaeological remains that includeing many prehistoric sites and other important stratified deposits. Such a narrow approach may also threaten .

is prehistoric lithic scatters[N1], peatland and alluvial deposits which although less obvious and dramatic than upstanding remains are often of equal or greater overall significance[N2], but which at present cannot even be designated and thus formally protected.

On the 27th July 2011, the equivalent Scottish Government document Planning Advice Note 2: Planning and Archaeology was published. Unlike the proposals for England this was a much more streamlined document, and in contrast to the somewhat subjective and nebulous concept of ‘significance’ contained in the draft National Planning Policy Framework, Planning Advice Note 2 (PAN2) suggests that planning applications will assess the relative merit of archaeological features according to its rarity, state of preservation, wider cultural or historical associations and its value for local communities as a potential educational or tourist resource if left in situ. This would appear to offer a clearer and more coherent set of criteria for assessing the significance of archaeological remains and guiding planners. Most importantly of all, PAN2 explicitly states that “It is essential that every planning authority has access to a Sites and Monuments Record (SMR)/Historic Environment Record (HER) (a record of all known sites), curated by a professional archaeologist on behalf of the local authority or a dedicated heritage body” (PLAN2: section 10). It then goes on to detail the services that should be provided by HERs. The National Planning Policy Framework makes no such commitments, however, and in England local authorities have already closed several Historic Environment Record offices and consequently in these areas planners are currently operating without any specialist archaeological advice.

should be concerned about its application (in practice planners and developers tend to just look for SMs). I take Stuart's point about broadening the reference to lithic scatters etc, but the issue with them specifically is that they can't at present be designated under the definitions in the 1979 Act, whereas other types of site could be put forward for scheduling.

appears to discriminate against below ground remains including many prehistoric sites and other important stratified deposits. In particular, this might threaten prehistoric lithic scatters[N3], peatlandand alluvial deposits which although less obvious and dramatic than upstanding remains aremightnonetheless often be of equal or if notand frequentlygreater overall significance[N4].

In order to fulfil the stated objectives of conserving the historic environment and making the information publicly available, the Prehistoric Society thus urges the Government to maintain the key existing principles of PPS5. It also calls on the Government to guarantee through legislation the statutory provision of Historic Environment Record offices by local authorities who shall provide them with adequate funding and resources to enable them to maintain effective archaeological input into the planning process, facilitate access for the public and researchers, and champion and promote the archaeology of their areas. Where local authorities have already withdrawn support for Historic Environment Record services, the Prehistoric Society urges that these services must be reinstated. This is imperative if ‘balanced judgements’, in which due balance is given to herheritage matters ,are to be achieved, and thus the Ggovernment’s own aspirations , as cited aboveare , are to be attained.

[N1]This might perhaps be broadened to ‘most prehistoric settlement sites and many other important stratified remains’. In which case, could drop over-specific reference tolithics,peatlands and alluvial contexts

[N2]And public interest?

[N3]This might perhaps be broadened to ‘most prehistoric settlement sites and many other important stratified remains’. In which case, could drop over-specific reference tolithics,peatlands and alluvial contexts

[N4]And public interest?