Historic England London Plan Review No.2 Report Final | September 2016 This report takes into account the particular instructions and requirements of our client. It is not intended for and should not be relied upon by any third party and no responsibility is undertaken to any third party. Job number 247256 13 Fitzroy Street London W1T 4BQ United Kingdom Historic England London Plan Review No.2 Report Contents Page Executive Summary i 1 Introduction 1 1.1 Purpose of the Study 1 1.2 Background 1 1.3 Aims and Objectives 2 1.4 Structure of this Report 3 2 Methodology 4 2.1 Overview of Stages of Work 4 2.2 Compliance Framework 4 2.3 Conservation Officers Survey 5 2.4 Case Studies 6 3 Compliance Framework 8 3.1 Policy 2.10 Central Activities Zone – strategic priorities 8 3.2 Policy 7.4 Local Character 9 3.3 Policy 7.7 Location and design of tall and large buildings 10 3.4 Policy 7.8 Heritage assets and archaeology 12 3.5 Policy 7.9 Heritage led regeneration 15 3.6 Policy 7.10 World Heritage Sites 16 3.7 Policy 7.11 LVMF 16 3.8 Policy 7.12 Implementing the LVMF 17 4 Conservation Officers Survey 19 4.1 Who responded 19 4.2 Relationship with Local Plans 19 4.3 Use of London Plan 19 4.4 Which London Plan policies are used 20 4.5 Weight given to London Plan policies 20 4.6 Benefit of London Plan policies 20 4.7 Suggested improvements 21 5 Case Studies 22 5.1 The Case Studies 22 5.2 Differences between decision makers 29 5.3 Analysis of policies 32 5.4 Weight given to London Plan heritage policies compared to other policies in the Plan 41 | Final | September 2016 Historic England London Plan Review No.2 Report 6 Findings and Recommendations 46 6.1 Overall Findings 46 Appendices Appendix A London Plan Policies Appendix B Conservation Officers Questionnaire Appendix C Compliance Framework Appendix D Case Study Proformas Appendix E Use of London Plan Heritage Policies by LPAs | Final | September 2016 Historic England London Plan Review No.2 Report Executive Summary Background London is a complex world city with a rich and diverse heritage. It is also a city which is subject to continual change. These changes present themselves as opportunities as well as challenges for the management of the historic environment. Much depends on the nature of the change, its scale, form and geographical location; successful management can be especially challenging when the pace of change is most intense. The planning system is one of the key ways that the historic environment is protected and enhanced in a way that balances local economic, social and environmental needs and ambitions. The execution of planning functions by Local Planning Authorities (LPA) and the Greater London Authority (GLA) is at the forefront of ensuring due consideration is given to heritage by enabling the successful management of change. The policies in the London Plan, along with national and local policy documents, create the framework within which applications are formulated and determined and are therefore of critical importance. This report analyses the application of heritage and other relevant policies of the London Plan in the management of the historic environment. It is intended to support Historic England in the approach it wishes to adopt as part of the review of the London Plan. Methodology The study was undertaken in four main stages: 1. Compliance Framework – assesses London Plan heritage policies against the National Planning Policy Framework (NPPF), National Planning Practice Guidance (NPPG) and Historic England Good Practice Guidance; 2. Survey of Conservation Officers - survey of London Conservation Officers to understand their views on the London Plan’s heritage polices and their application; 3. Case Study Review - review of 20 case studies for a range of developments across London to understand how the heritage policies in the London Plan were used during the determination of planning applications by the LPA, GLA and at appeal; and 4. Recommendations – draws together the findings of the compliance framework, survey and case studies to make recommendations. Findings and Recommendations The study finds that overall there is typically greater awareness, understanding and use of the heritage policies in the NPPF and local planning documents than the London Plan. The study has not found any evidence that this is due to the heritage policies themselves, rather it is a more general issue regarding awareness | Final | September 2016 Page i Historic England London Plan Review No.2 Report and application of the London Plan as a whole, relative to the related policy framework. The compliance framework finds that overall there is good alignment between the NPPF and London Plan, and the Conservation Officers survey indicates that similarly there is generally good alignment between local policies and the London Plan. It is therefore reasonable to assume that Officers are content to primarily draw on the national and local policies in decision making and only turn to the London Plan where it provides policies not found at the national or local level, for example the London View Management Framework (LVMF), or where it can add strength to a particular argument. The study’s key recommendations relate to awareness of the London Plan and its application as summarised below. In addition a series of policy specific recommendations are made in Section 6. Awareness and use of London Plan heritage policies In several of the case studies relevant London Plan heritage policies were not used to their full extent. This study has not found evidence that this occurs because the wording of the London Plan policy is not as good as it could be or the policy is misunderstood. Instead LPAs tend to rely on their own Local Plan policies and the NPPF, and the London Plan features less in consideration. The GLA also do not generally rely on London Plan policies in their Stage 1 and 2 Reports but consider proposals against its broader objectives. However where London Plan heritage policies are used in local and strategic decision making it is common for the policies to be identified as relevant but much less common for the proposal to be clearly and appropriately assessed against the policies. This is particularly noticeable in the lack of consideration given to understanding and assessing impact of proposals upon the significance of heritage assets. It is therefore recommended that awareness of the London Plan heritage policies and their application in development management is increased through a series of training, illustrative best practices and/or awareness raising events. Recommendation 1: Improve understanding and use of London Plan heritage policies and their application in pre-application and determination stages. This should be supplemented by provision of training for Borough and GLA Officers that demonstrates the value of applying the London Plan heritage policies when plan-making and determining proposals. To achieve this, consideration should be given to the GLA working with Historic England to develop a training package that ensures better understanding of heritage management. This should include illustrations of best practice for engaging in plan making for both planners and Conservation Officers. The case studies have also identified that there is an opportunity for Historic England to consistently reference the London Plan as part of the consideration of heritage policies in the submissions it makes on planning applications. Recommendation 2: Historic England consultation responses to routinely refer to London Plan policies. | Final | September 2016 Page ii Historic England London Plan Review No.2 Report Overarching London Heritage Strategy The NPPF requires local planning authorities to set out a positive strategy for the conservation and enjoyment of the historic environment in their Local Plan. It is recommended that Historic England and GLA consider as part of the London Plan review, producing a London Heritage Strategy which would meet the requirement for a positive strategy. The Strategy should address the requirements of the NPPF by championing London’s heritage as positively contributing to the future regeneration, development and management decisions for the city. The Strategy should provide a clear strategic approach to dealing with London’s heritage in the context of significant change, and support the delivery of sustainable growth. Furthermore, the Strategy should not be limited to planning, but be used as baseline for other relevant strategies that deliver the functions of the GLA, such as culture, regeneration, transport and land management. The Strategy should be informed by a robust evidence base for the historic environment which can be used to provide clear objectives for strategic management of the historic environment in London, that support the London Plan and its heritage policies. The GLA in partnership with Historic England should explore the scope of a Heritage Strategy for London, which would principally inform the development of policies in the London Plan that conserve and enhance its unique heritage in the context of national policy. As evidence the Strategy could then be adapted into SPG and form a complementary part of the suite of topic specific guidance which already exists. In considering the production of a Strategy, the recent recommendations of the Local Plans Expert Group should be monitored to establish which are taken forward. In particular the recommendation that plans should produce a proportionate assessment of environmental capacity consistent with the tests set at Paragraph 14 of the NPPF. Recommendation 3: The GLA in partnership with Historic England should consider producing a London Heritage Strategy in line with national policy. Monitoring The effectiveness of the London Plan is assessed through the London Plan Annual Monitoring Report which uses 24 Key Performance Indicators (KPI), one of which relates to heritage.