Historic England (HE) has issued its new Advice Note on ‘Statements of Heritage Significance’ (HEAN 12), and though it contains useful advice, uncertainties continue with regard to interfaces with government’s planning guidance in the National Planning Policy Framework (NPPF) as well as older heritage guidance.
IHBC Policy Secretary Roy Lewis said: ‘The recently published HEAN 12 provides useful advice on the preparation of statements of significance and takes account of a number of points raised by IHBC in response to the consultation draft. However, it does not resolve the confusion as to whether such statements should consider the impact of a proposal on heritage significance.’
‘Paragraph 189 of the National Planning Policy (NNPF) states that applicants should describe the significance of any heritage assets affected by a proposal, whilst paragraph 190 states that the local planning authority (LPA) should consider the impact of the proposal on that significance. Consequently, Government policy is clear as to respective roles. HEAN 12 acknowledges that a straightforward assessment of heritage significance satisfies the NPPF requirement on the applicant but goes on to promote consideration of impact in statements of significance and includes consideration of impact in its suggested structures for such documents (with the exception of the simplest cases).’
‘In its consultation response, the IHBC took the view that the respective roles as set out by Government should be adhered to. It can be difficult for consultants employed by developers to make impartial judgments regarding the impact of their client’s proposals and experience has shown that assessments of impact produced by applicants sometimes underplay the degree of harm that would be caused. It is open to applicants to explain how heritage significance has been respected in supporting documents such as a Planning Statement or a Design & Access Statement but it is for the LPA to determine the impact on that significance.’
‘The Advice Note reinforces the message that heritage significance is made up of archaeological interest, architectural and artistic interest, and historic interest. This is consistent with the words of statute, NPPF policy and Planning Policy Guidance (PPG). However, ambiguity remains due to the references to ‘heritage values’ in Historic England’s 2008 publication ‘Conservation Principles’. The terminology in this outdated document continues to cause confusion. There is now an urgent need for a suitably updated edition of ‘Conservation Principles’ (from 2008) in order to provide clarity and consistency to all involved in the production and assessment of statements of significance and other associated work.’
‘HEAN 12 sensibly encourages applicants to consider assessment of significance at an early stage. The IHBC considers that it is essential to carry out such assessment prior to commencement of design work. Production of statements of significance after the completion of design work, simply to satisfy application validation requirements, defeats a primary purpose of such documents: to ensure that interventions are conceived in an informed manner.’
Historic England writes:
This Historic England advice note covers the National Planning Policy Framework requirement for applicants for heritage and other consents to describe heritage significance to help local planning authorities to make decisions on the impact of proposals for change to heritage assets. Understanding the significance of heritage assets, in advance of developing proposals for their buildings and sites, enables owners and applicants to receive effective, consistent and timely decisions.
This advice note explores the assessment of significance of heritage assets as part of a staged approach to decision-making in which assessing significance precedes designing the proposal(s). It also describes the relationship with archaeological desk-based assessments and field evaluations, as well as with Design and Access Statements. Analysis of heritage significance may also be useful in development plan preparation, including site allocations and Minerals and Waste Local Plans.
This advice note is part of emerging Historic England advice and it will therefore be reviewed in the light of practice. Feedback is welcomed and should be sent to the following e-mail address – governmentadvice@HistoricEngland.org.uk – marked Statements of Heritage Significance HEAN 12.
See the IHBC’s consultation response linked from ‘Consultations‘
See Historic England’s Conservation Principles
See the CIfA statement on the Note