Planning portal: The problem with PPS5
Current planning guidance for the historic environment is urgently in need of a robust review, says Paul Velluet
The proposals for fundamental change in the structure and content of central government’s planning policy might be viewed at best with benign scepticism and at worst with outright cynicism.
With the prospect of the demise of the Planning Policy Statements, the abandonment of Regional Spatial Strategies and the creation of a single national planning framework, offering a ‘shorter, more decentralised and less bureaucratic’ approach to policy, it is reasonable to ask whether this will lead to greater consistency and coherence in planning policy.
Some have expressed fears that much practical and legally tested policy could be jettisoned, leaving a significant policy vacuum at a strategic level. Others have argued that the proposal offers the opportunity to rationalise and update existing policy and remove inconsistencies.
Assuming that policies for sustaining the historic built environment will be retained, a useful starting point should be a robust and searching review of that most controversial policy document, Planning Policy Statement 5: Planning for the Historic Environment (PPS5), issued by the Department for Communities and Local Government last March. If there is one policy document that needs attention before its inclusion in any national planning framework, it must be PPS5 – not so much in order to shorten it, but rather to give it the clarity and coherence it lacks and to recover some of the usefulness and certainty of the guidance that it superseded.
It is now 12 months since the sudden – and arguably premature – publication of PPS5 and it is time to review the document and to question whether it has aided or hindered the delivery of sound decisions and successful conservation outcomes. While some have welcomed those positive features of PPS5 that have improved upon the guidance contained in the earlier Planning Policy Guidance 15 (PPG15), many across the private sector and in local government have viewed key areas of PPS5 with a substantial degree of scepticism. The statement of government’s broad objectives is clearly most welcome, in particular, the three stated parts of the ‘overarching aim’ and the specific recognition that ‘intelligently managed change may…be necessary if heritage assets are to be maintained for the long term’, and the clear policies linking the protection of ‘historic assets’ to sustainability and climate change issues.
Welcome, too, is the clear acknowledgement of ‘proportionality’ in the level of detail required in any description of the significance of heritage assets affected by planning proposals, and the need to recognise that the greater the harm to the significance of a heritage asset, the greater will be the justification needed for any loss.
Much of the wording of PPS5 reflects the aspirations of the legislative reforms advanced, but then abandoned, by the last government. In this regard the authors of PPS5 have sought to bundle together policy relating to all kinds of ‘assets’ of architectural, artistic, historical, archaeological and landscape interest into one all-embracing statement, leading to the adoption of obscure language that is substantially inconsistent with that of existing legislation and offering scope for challenges in the courts.
Anomalously, the terms ‘preservation’, ‘special architectural or historic interest’, ‘preservation or enhancement’ and ‘character or appearance’ are conspicuous by their absence or sparing use. Instead, the term ‘significance’, which has little, if any, statutory basis, is repeated endlessly. Sadly, the terms ‘judgement’ and ‘discernment’ are missing altogether.
Above all, much of the advice in PPS5 presupposes and depends crucially upon the existence and free availability of readily accessible, accurate and up-to-date records and adequately resourced, experienced and knowledgeable conservation staff in local planning authorities and in bodies such as English Heritage – surely an increasingly questionable assumption today.
Troubling, too, are the inclusion in the document of a complex and awkwardly worded series of inter-related policies applicable to the demolition of unlisted buildings in conservation areas and the failure to provide any distinction in the relevant policies between ‘working buildings’ and what might be described as ‘cultural monuments’ with little, if any, beneficial use.
Further major change in planning policy would offer the opportunity to secure the urgent resolution of the deficiencies of PPS5. Such a revision is essential if certainty and consistency in decision-making in relation to the built heritage are to be recovered.
Paul Velluet is senior associate, conservation and planning, at HOK Architects