Response to Draft PPS 15

“…latest statement on conservation and planning is not fit for purpose…”

“Conserving our heritage is fundamental to the quality of life people enjoy in our towns and cities, yet we are concerned that the Government’s latest statement on conservation and planning is not fit for purpose”, says Debbie Dance, Chair of the Historic Towns Forum, commenting in the draft Planning Policy Statement 15: Planning for the Historic Environment (PPS15).

The Forum initially welcomed the publication of Draft PPS15 for consultation but, having now studied its content, it is extremely concerned and disappointed at certain of its messages. The Forum believes that it is fundamentally compromised by the failure to enact the Heritage Protection Bill, without which it appears vague and may be open to legal challenge.

Concepts such as ‘heritage assets’, ‘significance’, ‘Heritage Partnership Agreements’ and ‘local lists’ will have no statutory basis.

“The PPS needs a strong vision statement that endorses heritage in its own right and the Government must bring forward the legislation at the earliest possible opportunity”, urged Ms Dance.

While there are some details in the PPS that the Forum supports, it poses more questions than it answers, in particular by:

  • weakening protection by undermining the presumption in favour of retention of historic buildings and fabric;
  • relying on the untested concept of ‘significance’ as the basis for conservation;
  • weakness in dealing with the relationship between heritage conservation and climate change;
  • failing to show how conservation fits within the wider planning, social and economic responsibilities of local authorities;
  • failing to strengthen the protection of non-designated heritage in Conservation Areas;
  • failing to address landscape as part of the heritage;
  • the omission of disability assess issues; and
  • a superficial consideration of the resource implications for local authorities, for example in the preparation of Historic Environment Records.

A fundamental concern about the Policy Statement is that it sees heritage protection in isolation. In practice conservation of the broad cultural and historic environment is a multi-dimensional, multi-agency matter. It is not simply, or even largely, about the protection of a fixed heritage: the conservation of sense of place, identity and local distinctiveness are essential.

The draft PPS makes little reference to matters such as the public realm, historic streetscapes and undesignated heritage at risk; there is no mention of roads, statutory undertakers and management of the public domain.

Debbie Dance said, “The Forum is, however, pleased that a draft has been published for consultation as this has engendered a full debate around the ongoing issues of heritage protection. We are keen to work closely with the Government Departments and English Heritage to get effective guidance backed up by legislation.”

HTF response to draft PPS 15