IHBC responds to NPPF consultation: Calls time on insubstantial distinctions in levels of ‘substantial harm’, seeks new settings policies, and more….

IHBC consultations webpageIn its response to the revised National Planning Policy Framework (NPPF) the IHBC has urged government to call time on ‘substantial harm’ and ‘less than substantial harm’; to develop policies for setting, and to celebrate the differences between heritage types.

The IHBC has submitted its response on the consultation from the Ministry of Housing, Communities and Local Government on the revised National Planning Policy Framework (NPPF).

IHBC Projects Officer Fiona Newton said: ‘The IHBC response to the NPPF covered many of the NPPF chapters but referred much of this back to the impact of planning policy to the historic environment and the majority of the comment concerned Chapter 16 on ‘Conserving and enhancing the historic environment’.’

‘We urged the government to delete the concepts of ‘substantial harm’ and ‘less than substantial harm’, to develop policies specifically for setting and to move away from the universal policies for heritage assets and to celebrate the differences between each distinct type of heritage asset.’

Headline issues include:

  • Despite Government commitments to maintaining levels of protection, changes to the weighting of policies might cause harm to heritage as the relative status of heritage policy is reduced.
  • Concern over the continued use of heritage policies first used for PPS5 (March 2010), a document conceived to tie in with emerging heritage legislation that never came to pass. Such policies are now inconsistent with, and have an unsatisfactory relationship to, the statutory duties imposed by the Planning (Listed Buildings and Conservation Areas) Act 1990.
  • A ‘one-size-fits-all’ approach to the definition of heritage asset which fails to recognise the differences between scheduled monuments, listed buildings, and conservation areas.
  • Reuse of policies on on harm to significance.  Instead of the negative approach of avoiding harm these policies should take a more positive stance and should emphasise sensitive, well-informed management of change.
  • The retention of the distinction between ‘substantial harm’ and ‘less than substantial harm’ which is unhelpful and has resulted in much unnecessary argument in relation to planning decision-making. The Welsh Government has sensibly not found it necessary or appropriate to make the distinction between ‘substantial harm’ and ‘less than substantial harm’ in its Planning Policy Wales document.
  • A noticeable lack of policy protection for setting and development within or affecting the setting of a heritage asset.
  • The IHBC has supported other organisations including Historic England and the Historic Environment Protection Reform Group, a sub-group of the Historic Environment Forum, who, in commenting on this draft have suggested the rewording of the new Paragraph 185 to incorporate the staged approach to changes to heritage assets, carrying out a proportionate initial analysis of heritage significance and setting, leading to a further analysis of significance, setting, and impact.  Revised wording was suggested which IHBC endorsed in its response

See more IHBC consultations

Download the NPPF consultation response

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