Prehistoric Society response to the Government’s draft National
Planning Policy Framework
On the 25th July 2011 the Government 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] 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] 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 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 it does state 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), 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 include many prehistoric sites and other
important stratified deposits. Such a narrow approach may also threaten prehistoric
lithic scatters, peatland and alluvial deposits which although less obvious and
dramatic than upstanding remains are often of equal or greater overall significance,
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
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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.
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 be reinstated. This is imperative if ‘balanced
judgements’ in heritage matters are to be achieved, and the Government’s own
aspirations are to be attained.
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