Tuesday, 28 October 2014

“Historic Environment Good Practice Advice in Planning” - the MPA is not happy

The Mineral Products Association - the trade body representing quarry companies - is not happy with English Heritage. The MPA claims English Heritage’s draft Good Practice Advice (GPA) - a series of documents intended to help local authorities, applicants and other interested parties implement the historic environment policy of the National Planning Policy Framework (NPPF) - is "not in tune with the presumption in favour of sustainable development formalised by the NPPF". Its director of planning said:
It seems that English Heritage expects the planning system to protect heritage assets above all other interests and that is not how the planning system is supposed to be operating.
It is bothered that the previous advice "Mineral Extraction and Archaeology: A Practice Guide" - a document produced in 2008 by the Minerals and Historic Environment Forum (MHEF) - has been sidelined, "given only one brief mention in the draft GPA":
In complete contrast to the MHEF, the group that drafted the GPA was comprised almost entirely of heritage professionals. Unless English Heritage involves a broader range of interested parties in the production of the GPA, with a view to winning their joint endorsement to the final document, it seems unlikely that the planning system will afford much weight to what it says. That is also likely to result in a document that reflects a better balance of interests…
In other words, the MPA wants planning advice that better reflects the interests of its quarrying members, and that less reflects the interests of the UK's historic environment. The MPA champions the NPPF’s "presumption in favour of sustainable development", but that's the same document that says local planning authorities "should recognise that heritage assets are an irreplaceable resource [to be conserved] in a manner appropriate to their significance".

But what is in the draft GPA that has made the MPA so angry? Well, and bearing in mind we now have evidence of a settlement of Iron Age roundhouses at Straitgate, here are a few things that English Heritage, a statutory consultee in the planning process, says:

Note 1: The Historic Environment in Local Plans

On Local Plan site allocations - "The best way of ensuring that the selection of sites to be put forward for development supports the delivery of the conservation strategy within the Local Plan is to avoid the selection of sites that will harm the significance of heritage assets." [16]

Note 2: Decision‐Taking in the Historic Environment

On Archaeological and historic interest - "Archaeological interest, as defined in the NPPF, differs from historic interest… because it is the prospects for a future expert archaeological investigation to reveal more about our past that need protecting." [13]

On Assessing the proposals - "Heritage conservation is an objective of sustainable development, as are many other public benefits. The optimum sustainable scheme is therefore one that can clearly show that it avoids, minimises or mitigates conflict between heritage conservation and any other public benefits it may deliver. This may be achieved, for example, by reconsidering the means of providing the public service or benefit, the location or the design." [23] "For loss to be necessary there will be no other reasonable means of delivering similar benefits, e.g. a different design, other mitigation or, as a last resort, development of an appropriate alternative site." [24]

On Decision‐taking for assets with archaeological interest - "For sites with archaeological interest, whether designated or not, the benefits of conserving them are a material consideration when considering planning applications for development." [31]

On Recording and furthering understanding - "…records cannot deliver the sensory experience and understanding of context provided by the original heritage asset, so the ability to investigate and record a heritage asset is not a factor in deciding whether consent for its destruction should be given." [32]

On Public engagement - and remember all the initial hoo-ha and secrecy surrounding the archaeology at Straitgate in September? - "Where appropriate and possible, local planning authorities and the developer are advised to consider the benefits of making the investigative works open to and interpreted for the public and to include that as part of the written scheme of investigation. The results can contribute to a deeper sense of place, ownership and community identity. Promoting understanding will increase active protection for the historic environment. Opportunities for public engagement, proportionate to the significance of the investigation, could, for example, include enabling participation in investigation, providing viewing platforms and interpretation panels, jointly designed open days in partnership with the local community, public talks and online forums as well as coverage in local media." [45]

On Unexpected discoveries during work: "Where a new heritage asset is discovered or an existing known asset proves to be more significant than foreseen at the time of application, the local planning authority is advised to work with the developer to seek a proportionate solution that protects the significance of the new discovery, so far as is practical, within the existing scheme. Developers are advised to incorporate the potential for unexpected discoveries into their risk‐management strategies." [46]

So you can see why the MPA is concerned. It's not going to be in favour of anything - even something as important as the nation's historical and archaeological assets - that hinders the activities and profits of its multinational cement conglomerate backers. English Heritage's GPA is something for us all, including DCC, to bear in mind, as Aggregate Industries pushes on with its plans to bulldoze Straitgate Farm.

Nick Smith