BHM0005

Written evidence submitted by Historic England

Historic England is the Government’s statutory adviser on all matters relating to the historic environment in England. We are a non-departmental public body established under the National Heritage Act 1983 and sponsored by the Department for Digital, Culture, Media and Sport (DCMS). We champion and protect England’s historic places, providing expert advice to local planning authorities, developers, owners and communities to help ensure our historic environment is properly understood, enjoyed and cared for.

Overview

1)     Historic England supports the need to address issues of housing supply, and recognises the scale of the current challenge. Within this context, the rationale behind many of the recent changes to the planning system is understood, though it remains important to ensure that housing is not delivered at any cost, and that planning delivers homes rather than just housing, and places rather than just spaces. The historic environment has a key role to play in this regard.

2)     We welcome the opportunity to submit a response on the following points.

Planning Context

3)     Creating successful places requires functioning, attractive and distinctive environments which meet a range of needs in a range of ways. Current planning policy correctly encourages the release of under-utilised land and buildings, and the reallocation of land where the local planning authority considers there to be no reasonable prospect of an application coming forward for the existing allocated use (National Planning Policy Framework (NPPF), paragraphs 118 and 120). It also encourages local planning authorities to use retail and employment land for homes in areas of high housing demand – provided that this would not undermine key economic sectors or sites or the vitality and viability of town centres (NPPF, paragraph 121). This reflects a shift in overall policy towards encouraging housing at the potential expense of other uses which meet the wider needs of present and future communities, and of the mixed, vibrant and distinctive character which is so important to many places, and informs the character of many conservation areas.

4)     A related concern is the implementation of the Housing Delivery Test. This has the potential to disincentivise housing delivery, as failure to deliver existing consents can result in a local planning authority having to make further housing site allocations, thereby penalising local planning authorities – and their communities – for developers’ failure to implement planning consents. 

5)     More specific proposals undermine the generally appropriate balance which the NPPF strikes between housing delivery and the consideration of other matters, such as heritage. One such is the proposal for upwards extensions (NPPF, paragraph 118), subsequently confirmed as a proposal for a new permitted development right, to be introduced in the autumn. This proposal is more likely to deliver larger rather than additional housing, and will certainly not contribute to overall housing stock sufficiently to justify the anticipated impact on the wider environment, including the historic. Whilst the exclusion of Article 2(3) land (which includes conservation areas and world heritage sites), listed buildings (and their curtilage), and scheduled monuments is welcomed, this would not address the impact on the other designated and non-designated heritage assets and their setting, nor the general quality and character of the built environment. There is likely to be harm to the historic environment from both individual proposals and the cumulative effect of a number of proposals, and an associated failure to deliver sustainable development.  

6)     Historic England regards this as a wholly unnecessary measure in historic areas – and an unnecessarily complicated one – which removes the ability to consider the relevant issues adequately in the round. Instead, efforts would be better directed into encouraging wider, more proactive use of existing powers, promoting good design in any such developments, and identifying locations where upwards development would be particularly appropriate.

7)     Overall, national policy (and initiatives such as the Building Better, Building Beautiful Commission) press for high quality design, and the conservation and enjoyment of the historic environment, and this is very much welcomed. It will be very important to ensure that housing delivery is achieved in conjunction with – rather than in opposition to – these objectives.

Contribution of Heritage

8)     The historic environment provides a sense of continuity and stability, and also helps to create and reinforce a sense of place. Far from being an obstacle to development, our heritage has been shown to be a catalyst for housing development and regeneration, and ‘good growth’, as shown in Translating Good Growth for London’s Historic Environment.

9)     Starting with the contribution of heritage to housing delivery, analysis of Valuation Office Agency (VOA) data demonstrates that the historic environment has an important role to play in the provision of additional housing. According to VOA data (see table below), the total number of pre-1919 dwellings in England increased by 51,110, between 2012 and 2018.[1]

Source: Valuation Office Agency – Council Tax: Stock of Properties

10) Figure 1, below, maps the change in pre-1919 dwellings between 2015 and 2018. This identifies key growth areas in the south and east of England occurring in historic towns and cities such as Norwich, Brighton and Bristol: this change is likely to be driven by the subdivision of larger historic properties into smaller dwellings. Alternatively, key growth areas in the Midlands and the north occur in former industrial towns and cities, such as Birmingham, and across Lancashire and Yorkshire: this growth is likely to be driven by the conversion of former industrial buildings into residential dwellings.

Figure 1 – Increase in numbers of pre-1919 dwellings, 2015-18, by Mid-level Super Output Area (MSOA)

11) The full contribution of the historic environment to the government’s housing agenda has yet to be realised. Our research indicates that vacant or underused former textile mills across Lancashire and the West Riding of Yorkshire have the space to contribute another 52,000 homes.[2] Historic England is working with local authority and sector partners to realise this potential.

12) An example of both housing delivery and wider regeneration (which also demonstrates the impact of adaptive re-use of historic buildings) can be seen in our recent publication Heritage: The Foundation for Success. The Old Vinyl Factory (Hayes, London) is a £250 million scheme which will deliver 642 new homes and 750,000 sq. ft. of commercial and leisure space in a distinctive and innovative mixed-use scheme. It introduces new development amongst original Art Deco buildings, and respects the area’s industrial and musical legacy. 

13) Historic England’s forthcoming ‘High Street Heritage Action Zones’ scheme, funded by Government, will deliver a four-year programme of physical improvements and cultural activities to regenerate struggling historic high streets and town centres – including housing – in partnership with local authorities, Business Improvement Districts, Chambers of Commerce and community groups.

14) In terms of the general impact of heritage on development, the rate of new development in conservation areas has been shown to be close to the national average,[3] and residential prices in conservation areas are on average 23% higher than outside conservation areas.[4] Even if the unit cost of construction is slightly higher inside Conservation Areas compared to areas beyond their boundaries, such areas are likely to offer attractive development opportunities.

15) Recent Historic England research also demonstrates that residential development can be delivered sensitively and successfully at the higher densities that the National Planning Policy Framework requires. Increasing Residential Density in Historic Environments reviews a number of case studies to explore ways in which densities of up to 312 dwellings per hectare can be accommodated within a historic context, and makes recommendations to further promulgate good practice.

16) Heritage is known to be important to businesses. The quality of the historic environment is as important a factor as road access when businesses decide where to locate.[5] The number of businesses operating in listed buildings across England rose by 18% between 2012 and 2018, with particular increases for retail (154%) and food and drink brands (173%).[6] Just over two-thirds of commercial occupiers believe that historic buildings give a positive image to customers and clients.[7]

17) Heritage is also of benefit to communities, with 87% of people believe that finding new uses for historic buildings is better than demolishing them.[8] People who live in areas with more heritage assets are also likely to have a stronger sense of place.[9]

18) Further Historic England research into the Heritage Dimension of Planning Applications has demonstrated that 26% of planning applications had a heritage dimension; 91% of these were granted planning permission. Figures from MHCLG further confirm that listing is not a barrier to development: between January and March 2018, only 6.9% of Listed Building Consent applications were refused (in comparison, 9% of householder applications were refused planning permission, 18% of major dwelling applications, and 27% of minor dwelling applications). In addition, the majority (79.7%) of Listed Building Consent decisions were decided within 8 weeks.

19) As noted in national planning policy, the key is in understanding what you have, what is important about it, and how it can inspire high quality new development.

Local Planning Authority Pressures

20) Reference has been made above to the potential impact of the Housing Delivery Test. A further concern is local planning authority access to conservation expertise. As outlined in the Tenth Report on Local Authority Staff Resources, the numbers of conservation and archaeological specialists providing advice to local authorities in England have both fallen by 35% since 2006, which does not support the most efficient or effective application of planning policy and legislation (see Figure 2, overleaf). Planning departments overall have suffered disproportionately in local authority budget cuts.

21) Alongside these challenges is an increase in proposed permitted development rights, which remove key proposals from local decision-making, do not generally yield planning fees to offset costs, and also result in development that has a local impact but does not contribute to mitigation through developer contributions. The Government has also recently announced a renewed emphasis on speed in decision-making: an ‘Accelerated Planning’ Green Paper will be published later this year that will discuss how greater capacity and capability, performance management and procedural improvements can accelerate the end-to-end planning process (drawing on the Rosewell Review of planning appeal inquiries). It is to be hoped that the encouragement of quality outcomes is included alongside procedural efficiencies.

Figure 2 – Change in Local Authority Historic Environment Staff (2006-2018)

Source: Historic England, IHBC, ALGAO

Historic England’s Support for Housing Delivery and Place-Making

22) Place-making is the process used to shape public spaces and buildings. Rooted in community-based participation, it involves planning, design, and management, and brings together diverse people (including professionals, elected officials, local groups, residents, and businesses) to improve a community’s cultural, economic, social and environmental situation. It is often best achieved through a clear understanding of the historic significance of the existing place.

23) The Historic England Places Strategy sets out how we will help communities to transform the places they love, using the historic environment to deliver public value and demonstrating the catalytic effect it can have for good.

24) Historic England’s practical support for housing delivery and place-making takes a number of forms, including:

• Timely planning advice on strategic, local and neighbourhood plans, as well as on individual applications (where more than 98% of our planning and listed building consent advice to local authorities is provided within statutory or otherwise agreed deadlines), helps to identify ways to protect and enhance heritage whilst enriching and inspiring new development. Where additional speed and certainty are required, we offer a range of paid-for services (in addition to our free services), such as extended pre-application advice.
• Research (including our characterisation projects) provides a deeper understanding of places, as well as the ways in which housing can be delivered (such as our report on Increasing Residential Density in Historic Environments).
• Designation identifies and defines the most important historic elements of a place from a national perspective (listed on the online National Heritage List for England). Again, where additional speed and certainty are required, we offer a range of paid-for services (in addition to our free services), including fast-track listing, listing enhancement, and screening for potential listing.
• Historic England runs a number of grant schemes to help with the cost of caring for various buildings, monuments, areas and landscapes, and to develop new methods for planning and conservation.
• Through our Heritage Action Zones initiative, we are working to breathe new life into old places (including housing delivery). 

April 2019

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