should be avoided (para 2.8). Instead, the role of supplementary guidance is stressed (para 2.5). As to development control, the PPG emphasises the need for appropriately qualified specialist advice to be given on any development affecting the historic environment, and for the design of new buildings in such areas to be very carefully considered. Slightly more substantial guidance is given (in Chapters 2 and 6) on world heritage sites, historic parks and gardens, and historic battlefields; and a new section in each Chapter deals with the wider historic landscape. 3 LISTED BUILDING CONTROL This Chapter is perhaps the heart of the PPG. It first considers briefly the need for listed building consent - albeit not in any detail - and then sets out the criteria on which applications should be determined. The guidance now starts (in para 3.3) with a clear "general presumption in favour of the preservation of listed buildings" (which had been dropped in the draft). It also places the burden firmly on applicants ro justify their proposals, and to supply sufficient information to enable them to be assessed. The general criteria, relevant to the consideration of all listed building consent applications (that is, for demolition or alteration) are set out at para 3.5, as follows: (i) the importance of the building (cf Circular 8/87, para 90(a)); (ii) the physical features of it which justify its inclusion in the list (cf para 90(6)); (iii) its setting and its contribution to the local scene (cf para 90(a)); and (iv) the extent to which the proposed works would bring substantial benefits to the community. We shall all, no doubt, soon know these by heart. The PPG helpfully clarifies the extent to which its policies on the alteration of listed buildings apply also to their partial demolition, and vice versa. The question of use is also discussed (at paras 3.8 to 3.11). As in the draft, no itemised criteria are given in relation to alterations - perhaps that is inevitable, given the diverse nature of proposals - but the general approach to be adopted is set out at para 3.13. The considerations to be addressed in relation to applications for total or substantial demolition, on the other hand, are as before itemised, as follows: (i) the condition of the building, the cost of repairing and maintaining it in relation ro its importance and the value derived from its continued use (cf Circ 8/87, para CONTEXT 44 90(c)); (ii) the adequacy of efforts made to retain it in use; and (iii) the merits of alternative proposals for the site (cf para 90(d)). The remainder of the Chapter deals with various points of detail, including building control and fire legislation; renovation grants; local authority applications; Crown buildings; consent for works already carried out; enforcement; and prosecution. In particular, material is introduced for the first time referring to the Secretary of State's policy on calling in applications (paras 3.20, 3.21); the recording of buildings (paras 3.22-3.24); the modification of historic buildings to allow for disabled access (para 3.28); and the use of injunctions (para 3.48). There is also expanded advice on fixtures and curtilage structures (paras 3.30-3.36) - a notoriously difficult area in practice. The only (admittedly slight) error would seem to be in the implication (at para 3.36) that an object is probably "fixed" to a listed building if it is specifically included in the listing. Chapter 3 of the PPG needs to be read together with Annex B (on procedures) and Annex C (detailed guidance on alterations). Annex B is straightforward, but so brief that it is unlikely to be of great use in practice; it is also (inevitably) already slightly inaccurate Circular 6/85 (on compulsory purchase) has been replaced with Circular 14194. Annex C is almost entirely unchanged from Annex 4 in the draft - except that its paragraph numbering has been greatly improved. It is still a good general introductory guide, especially if read alongside the English Heritage manual to which it refers. The Annex in the draft PPG relating to conditions on listed building consent (which repeated the similar Annex to Circular 8/87; has been removed. Its loss is however not greatly to be regretted; most conditions need to be carefully drafted to suit the specific circumstances. 4 CONSERVATION AREAS The section of the PPG on the designation of conservation areas is broadly as in the draft, but it too has been expanded, not least by reference to the guidelines recently produced by English Heritage. The advice (sensible in itself) in the draft on the need for local authorities before designating an area to consider the resource implications has been balanced - correctly - by a new comment that the primary concern is the actual quality of the area. The PPG also deals with the new provisions introduced in the Leasehold Reform etc Act 1993 relating to estate management in conservation areas. Expanded guidance is given on trees, which are a major feature in the appearance of many conservation areas - and indeed in the setting of a number of listed buildings. The guidance (and indeed the legislation) on this topic is still however woefully inadequate; Circular 36/78 is now significantly out of date. Further action is urgently needed here. 5 TRANSPORT AND TRAFFIC MANAGEMENT Most noticeable of all the new material in is the brand new Chapter on transport and traffic management in historic areas, which follows on from the emphasis on sustainable development and the new approach in "the recent PPG 13. This Chapter accordingly discusses new traffic routes; schemes under the Transport and Works Act (see Context 38); roads in centres of settlements; and a greatly expanded section on floorscape and street furniture. All this is no doubt admirable; but it is to be hoped that this guidance is brought to the attention of those who need it - in particular highway authorities - and not merely used by those opposing them. 6 IDENTIFY1NG AND RECORDING THE HISTORIC ENVIRONMENT The material in this Chapter, formerly tucked away as an Annex, is preceded by a thoughtful introductory section. Otherwise, it contains few surprises. The criteria for listing are set out (architectural interest; historic interest; close historical associations; and group value). As in the draft, however, no clear criteria are given relating to the grading of listed buildings; the only clues are dotted around elsewhere in the PPG (see paras 3.6, 3. 14 and 3.17). The Chapter also deals with the overlap between listing and scheduling, as well as world heritage sites, historic parks and gardens, historic battlefields and the wider historic landscape. 7 REPAIRS The section of the PPG on repairs is also given greater prominence by being brought into the main body of the text. It is actually still quite thin, however, which is disappointing - particularly as this is an area where local authorities may have to put their hands in their pockets, and strong moral support from central Government would thus be particularly welcome. 8 CHURCHES AND THE ECCLESIASTICAL EXEMPTION This section has been considerably expanded from the annex in the draft 21
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