Royal Tunbridge Wells Civic Society

Royal Tunbridge Wells Civic Society

Reg Charity No 276545

23 Claremont Road

Tunbridge Wells

Kent TN1 1SY

Mr P Weatherby

Communities and Local Government

Planning Systems Improvement Division

Eland House

Bressenden Place

London SW1E 5DU21 October 2009

Dear Mr Weatherby

I have pleasure in attaching the response of the Society to the consultation on the draft PPS15: Planning for the Historic Environment.

We are surprised by the timing of this consultation. In the absence of legislative changes, such as those in the Heritage Protection Bill, we are not sure how real and substantial the policy changes described in the draft actually are. It seems quite likely that legislative changes will occur soon to make the draft out of date, certainly well before the twenty years referred to in question 10.

We value the separation of policy from guidance but do not find the overall effect of the draft proposals to be `streamlining`, either in effect (they could require a great deal more work), or in the somewhat rebarbative form of the document. We believe an effective consultation in the present situation could have been much shorter and clearer.

We thus favour Option 1, with if necessary non-statutory guidance to local authorities on extending their responsibility towards all heritage assets.

Yours sincerely

A R Tod (Dr)

Chairman RTWCS

PART 4: Consultation Questions

Questions on which we would particularly like your views:

1. Does the PPS strike the right balance between advocating the conservation of what is important and enabling change? The question is inappropriate: it is not for a Policy Statement on Conservation to enable change. It should seek to ensure certain standards in change, including the preservation/incorporation of historic assets.

2. By adopting a single spectrum approach to historic assets, does the PPS take proper account of any differences between types of asset (eg. are archaeological assets adequately covered)? Possibly not. The provision for developers to report on the archaeological value of sites is unrealistic. The policies do not appear to relate to marine sites.

3.In doing so, does the PPS take appropriate account of the implications of the European Landscape Convention, and of the cultural dimensions of landscapes designated as National Parks and Areas of Outstanding Natural Beauty? The cultural dimensions of designated landscapes and the artistic value of heritage assets are not properly defined. We also have difficulty with the concept of `significance`(see 5 below).

4.Are the policies and principles set out in the PPS the key ones that underpin planning policy on the historic environment, or should others be included? We welcome the broadening of the category to include non-designated assets but find the attempt to isolate `heritage` mistaken; in the absence of legislation we doubt the effectiveness of policy towards the more ordinary assets. We would like reference to the value of conserving the commonplace - embodied energy etc.

5.Do you agree that it is the “significance” of a historic asset that we are trying to conserve? Where there is agreed significance (eg. in terms of community values) yes. In most other cases historic assets should be preserved for their own sake, in the knowledge that `significance` can change utterly with time.

6.Does the PPS comply with devolutionary principles with regard to what is expected at regional and local levels? We believe the appropriate level for implementing conservation policy is the local one.

7. Does the PPS strike the right balance between the objectives of conserving what is significant in the historic environment and mitigating the effects of climate change? We welcome the emphasis on finding suitable alternative measures to protect buildings and landscapes. We would like to see more attention given to the conservation of resources, including built fabric.

8.Does the PPS make it clear to decision-makers what they should do, and where they have more flexibility? Are there any risks or benefits you would like to highlight for the historic environment sector? We welcome the policies for local authorities maintaining a Historic Environment Record (HE1.1), to setting out a positive strategy for conservation (HE3.1), and to making use of Article 4 directions (HE5.1). But the wording of the PPS is often unclear, and frequent references to `where appropriate` tend to weaken policy. The chief danger is that the PPS will be seen as encouraging incompatible development of historic assets with partial or token preservation of the asset as a `price`.

9. The draft PPS highlights the importance of ensuring that adequate information and evidence bases are available, so that the historic environment and the significance of heritage assets are fully taken into account in plan-making and decision-taking. At the same time we are concerned to ensure that information requirements are proportionate and do not cause unnecessary delays. Are you content we have the balance right? If not how would you like to see our policy adjusted? (Policies HE8 and HE9 are particularly relevant to this question.) We do not have confidence in `descriptions of the significance of heritage assets` provided by developers; it is for local authorities responding to their local communities to determine the significance of assets and the value of development. We are concerned by the reference to `unnecessary delays` - where historic assets are concerned due attention to preservation, restoration and/or reuse will require more time than other applications.

10.In your opinion is the PPS a document that will remain relevant for at least the next 20 years? Do you see other developments on the horizon that have implications for the policies set out in the PPS? a) We find this very unlikely. b) None specific but good reason to expect change.

11.Do you agree with the conclusions of the consultation stage impact assessment. Inparticular, have we correctly identified and resourced any additional burdens for local planning authorities? Is the impact on owners/developers correctly identified and proportionate to their responsibilities? We do not believe it is possible to forecast costs and benefits in this case.

12.Do you think that the policy draft PPS will have a differential impact, either positive or negative, on people, because of their gender, race or disability? If so how in your view should we respond? We particularly welcome the views of organisations and individuals with specific expertise in these areas. No, and we welcome the emphasis given to the views of local communities and the recognition of non-designated assets in local lists etc.

Royal Tunbridge Wells Civic Society (Reg Charity No 276545)

10th October 2009