House of Commons Communities and Local Government Committee Planning Practice Guidance Written Evidence received up to 23/01/13 Only those submissions written specifically for the Committee and accepted by the Committee as evidence for the Planning Practice Guidance inquiry are included. 1 List of written evidence Page British Property Federation (PTG 13) ................................................................................................ 42 Building Research Establishment (PTG 02) ......................................................................................... 6 Campaign for Better Transport (PTG 04) ......................................................................................... 13 Campaign to Protect Rural England (PTG 26) .................................................................................. 85 Chartered Institution of Highways and Transportation (PTG 16) ................................................... 52 Country Land Association (PTG 06) ................................................................................................. 18 Design Council (PTG 17) .................................................................................................................... 57 Engligh Heritage (PTG 11) .................................................................................................................. 36 Heritage Alliance (PTG 07) ................................................................................................................ 22 Historic Houses Association (PTG 18) ............................................................................................... 59 Home Builders Federation (PTG 03) .................................................................................................. 10 Institute for Archaeologists (PTG 01) ................................................................................................. 3 Institute of Historic Building Conservation (PTG 24) ...................................................................... 76 Law Society of England and Wales (PTG 05) ..................................................................................... 15 Living Streets (PTG 14) ....................................................................................................................... 46 Local Government Association (PTG 25) ........................................................................................... 78 Planning Officers Society (PTG 12) .................................................................................................... 39 Renewable UK (PTG 21) ...................................................................................................................... 69 Residential Landlords Association (PTG 08) ..................................................................................... 24 Royal Institute of Chartered Surveyors (PTG 22) .............................................................................. 71 Royal Town Planning Institute (PTG 10) ........................................................................................... 32 Spatial Planning and Health Group (PTG 15) ................................................................................... 48 SSE (PTG 23) ........................................................................................................................................ 73 Theatres Trust (PTG 20) ..................................................................................................................... 64 Town and Country Planning Association (PTG 09) .......................................................................... 28 UK Green Building Council (PTG 19) ................................................................................................ 62 2 Written evidence submitted by the Institute for Archaeologists (PTG 01) 1. Summary 1.1. IfA agrees with the Review Group that there is not presently ‘an effective suite of planning practice guidance to support plan making and development management by the sector as a whole, nor is it in a form which can be effectively managed and kept up-to-date’. 1.2. With regard to the historic environment, IfA also agrees that PPS5 Planning for the Historic Environment: Historic Environment Practice Guide (2010) (Review Report, Annex C, document 31) should be replaced by revised guidance and accepts that this may involve a substantial reduction in the length of that guidance. 1.3. Such high-level guidance should nonetheless address the following (amongst other things) in relation to archaeology • clarification of the concept of ‘archaeological interest’ • recognition of the importance of undesignated heritage assets in the planning system • the advantages of development-related, archaeological work being carried out by competent, accredited practitioners working in accordance with professional standards. 1.4. Furthermore, policy and guidance ‘does not necessarily achieve clarity by virtue of its brevity1’. Although IfA supports the National Planning Policy Framework in its current form, it does require detailed elaboration in guidance. Much of the detail in PPS5 Planning for the Historic Environment: Historic Environment Practice Guide (2010) and the draft Historic Environment Forum (HEF) guidance (which improves upon the earlier document) should be viewed as necessary guidance on what is required in considering applications relating to the historic environment (‘minimum compliance’) rather than discretionary good practice. If all of this cannot be included in high-level, Government-endorsed guidance, then it should at least be signposted in that guidance and produced by the sector with the support of Government. 1.5. In addition to guidance on the minimum requirements of the National Planning Policy Framework (such as the HEF draft and IfA Standards and guidance), the Review Group notes the value of good practice guidance (such as the ‘clients’ guide to archaeology’ presently under development by IfA). IfA remains committed to the continuing development of good practice guidance for the historic environment. 2. Introduction 2.1. The Institute for Archaeologists (IfA) is the professional body for archaeologists and related professions concerned with the study and care of the historic environment. It promotes best practice in archaeology and provides a self-regulatory quality assurance framework for the sector and those it serves. 1 CLG Committee Report: The National Planning Policy Framework, HC 1526, page 3 3 2.2. The IfA has over 3,200 members and more than 70 registered practices across the United Kingdom and abroad. Its members work in all branches of the discipline: heritage management, planning advice, excavation, finds and environmental study, buildings recording, underwater and aerial archaeology, museums, conservation, survey, research and development, teaching and liaison with the community, industry and the commercial and financial sectors. 2.3. IfA has responsibility for setting practice standards for its members in the public interest. 3. Response to Specific Questions (1) Has the Review Group gone far enough in reducing and consolidating guidance? If not, what changes need to be made? 3.1 Yes. If anything it has gone too far. In an ideal world, it is true that regulations, SIs and policy ‘should be written clearly in the first place’ (Review Group Report, page 6)2 but in reality detailed guidance is required, particularly when the emphasis in policy is upon brevity. (As this Committee noted in considering the National Planning Policy Framework last year3, brevity is not necessarily synonymous with clarity.) 3.2 That is not to say that IfA takes issue with Lord Taylor’s basic premise that there is currently too much planning guidance, much of which is outdated, obscure and inaccessible. We are simply, respectfully saying that ‘you should not throw out the baby with the bath water’. (2) Has the Review Group identified the correct priorities for the new guidance? What priority and timescale should be given to this over the cancellation and consolidation of existing guidance? 3.3 IfA wishes to see the revision of PPS5 Planning for the Historic Environment: Historic Environment Practice Guide (2010) included as an urgent priority to ensure the continued protection of the historic environment. We commend the HEF draft for its clear explanation of the responsibilities under the National Planning Policy Framework of applicants and planning authorities, but there is also an urgent need for good practice guidance. (3) Have any items been missed or excluded that should be included? 3.4 See above. (4) Is the timetable recommended by the Review Group realistic? 3.5 The timetable is challenging, but might be achieved (at least with regard to the historic environment) if the historic environment sector is fully and promptly engaged in the process. 2 Even when policy is clearly written there can still be problems. For instance, the need for a historic environment record (HER) made clear in the National Planning Policy Framework (paragraph 127) has been misinterpreted by some local authorities who seek to refute the need for a HER. The answer to this problem would be a statutory duty on local authorities to have access to a properly maintained HER. 3 CLG Committee Report: The National Planning Policy Framework, HC 1526, page 3 4 (5) Who will carry out the additional work of consolidation, producing new guidance and designing a web-based resource? What are the