Comment
Heritage in the planning White Paper: Is beauty still in the eye of the beholder?
As the consultation on the Government’s planning White Paper ‘Planning for the Future’ closes, Claire Easton in our Heritage team considers the heritage implications of this potentially momentous shift in planning direction.
It is encouraging to read in the foreword that a guiding principle of the document has been to ‘cherish’ the past. The aim to seek a simpler, faster and more predictable planning system is one I expect all would support.
However, for a document containing a significant number of beautiful images of heritage buildings and sites, written content relating specifically to the historic environment is surprisingly limited.
Pillar One – Planning for development
Pillar One of the document sets out a new approach to Plan-Making, with a new streamlined system allocating land at that stage into one of three areas, for growth, renewal or protection. Sites identified within growth areas would automatically be granted planning permission, and those within renewal areas would have a statutory presumption in favour of development. Whilst allowing for more certainty and clarity in the process, it is not clear how impacts upon heritage assets in these areas will be addressed. Whist the allocation of conservation areas into the ‘protected’ areas is straightforward, heritage assets will inevitably exist in growth and renewal areas and their significance and setting will need to be taken into account during decision making.
Similarly, the framework should be flexible enough for newly discovered heritage assets or new understanding of assets to be identified and for impact upon them to be considered, even in growth or renewal areas. This will also apply to the potential for archaeological remains.
The White Paper suggests that conservation areas would be allocated as ‘protected’ areas, and a process rather like the existing would apply. This suggests that for many of our city and town centres, there will be little change to the current arrangement.
This new approach front loads decision making, requiring that an understanding of the significance of heritage assets is established at the local plan stage, including potentially the drafting of conservation area appraisals, and the preparation of a register of locally listed buildings where these don’t already exist. This is a positive step, introducing consistency in an existing inconsistent system. Historic England already map and record listed buildings, but a question arises on setting. Setting, as anyone involved in the historic environment knows, is notoriously subjective and varied and cannot easily be mapped. In this new map-based plan, how will setting be dealt with? It is notable that the White Paper makes no mention of heritage setting at all, though suggestion is made that key views could be mapped and protected.
Pillar Two – Planning for beautiful and sustainable places
Pillar Two positively identifies that the Government wants a planning system that enables the creation of beautiful places. However it does raise the question, who decides what is beautiful? We all know that beauty is in the eye of the beholder, but is there a risk that this approach could lead to strong differences of opinion, or does an opportunity exist for better engagement, ensuring that proposals take into account the views of all stakeholders.
Many heritage sites are not conventionally ‘beautiful’, for example Brutalist buildings, or industrial complexes, but they may still be significant and valued. It is notable that the discussion of the re-use of the heritage environment is limited in this section of the White Paper, but clearly our shared heritage is often integral to the ‘beauty’ of many of our places.
The suggested use of Pattern Books and Design Codes can ensure high quality, sensitive and appropriate developments, but these must be prepared in the local context. The suggestion that in the absence of local guides, national guidance will prevail, potentially brings the cherished variety and distinctiveness of our historic places under threat.
Proposal 17: Conserving and enhancing our historic buildings and areas in the 21st Century
The Government is keen to promote the contribution that heritage assets can make to long term zero carbon objectives, but it will remain important that conservation is at the heart of decision making. It is also important to acknowledge that heritage assets are a finite resource and that the preservation of the assets for the future is in itself a key aspect of sustainability.
The aspiration to reduce the workload and paperwork associated with small scale applications for planning permission or listed building consent affecting heritage assets is sensible, and existing provisions do exist such as Local Listed Building Consent Orders and Local Development Orders. A potential solution could involve a new framework agreement through which minor consents could be granted. This could include a standardised ‘retrofit’ approach for consistent building typologies/ areas, but be administered at a local or regional level allowing for the preservation of local distinctiveness.
The White Paper proposes the use of suitably qualified architectural specialists who would have earned autonomy from routine Listed Building consents, something that has been hinted at before. Due to the complexity and subjectivity of heritage significance it would be necessary to rigorously define what is meant by ‘routine’ consents and to ensure that these decisions are taken in an informed and robust manner. This approach should embrace all heritage specialists, rather than just architects, but perhaps a better approach would be to better resource Local Planning Authorities so that this role could be undertaken by conservation officers.
Get in touch
Turley has made formal representations to the White Paper and we will be watching with interest to see how this significant set of changes progress. If you’d like to discuss the implications of the White Paper for your development or site please do get in touch.
29 October 2020