Written evidence submitted by the Heritage Alliance [FPS 066]



5. What is the best approach to ensure public engagement in the planning system? What role should modern technology and data play in this?


A crucial feature of the planning system is accountability and the opportunity for communities to feed into plans in their area. The Secretary of State has stressed that local democracy will not be lost in the Government’s new planning system. However, restricting community engagement to the Local Plan making stage will result in members of the public losing their ability to scrutinise individual planning applications.


We support the use of technology, but there also remains an issue around access to high-speed internet  - particularly in rural areas - and digital skills. Good Things Foundation estimates that 9m people in the UK struggle to use the internet independently and are being left out. Barriers to accessing the internet should not stop those who wish to register their thoughts on a planning proposal.


An important concern for the heritage sector is how to have an effective evidence base that allows for easy understanding of the heritage in or around an area or site planned for development when many important historical records are not digitised. There is not, as yet, one solid database that shows all the areas of heritage across England. Historical records must be properly considered in the process, even if it is not possible to do this digitally. Historic Environment Records  (sometimes referred to as Sites and Monuments Records) are one of the key sets of data on which a “data-led planning system” must rely on. These will need to be resourced and made accessible for the whole country.  We support proposals for accessible web-based Local Plans so long as the historic environment information can be an overlay and this can be made available and accessible to all.


The language in Proposal 7 of the Planning White Paper that Local Plans will be "based on the latest digital technology" is a concern in light of the Government’s eagerness to award contracts to private companies to create bespoke solutions that require overly-complex user registration, training, support etc. Use of open, common and familiar standards and platforms - e.g. Open Street Map or even Google Maps - reduces barriers to adoption and should be considered.  This route can also provide value for money for the taxpayer as it uses tools and platforms that already exist and function effectively, rather than investing in something completely new and untested. If, however, the Government decides to commission bespoke digital tools from private companies, they must ensure that the platform and process is not inaccessible to individuals, communities and the heritage sector.  Proposal 7 also states “interactive, map-based Local Plans will be built upon data standards and digital principles”. We think this should reference open data as a specific consideration.


6. How can the planning system ensure adequate and reasonable protection for areas and buildings of environmental, historical, and architectural importance?


The planning system is central to the beneficial management and protection of the historic environment and provides the only effective protection for many heritage assets. The Government must recognise that the natural and historic environment is not found only in their proposed ‘Protected’ zones but in ‘Growth’ and ‘Renewal’ zones too. Indeed, much of it yet to be discovered (e.g. buried heritage assets archaeology or the many buildings of listing quality that have not yet been listed) or part of a wider historic landscape (parks and gardens, battlefields, monuments, historic places). It is unclear whether or how these features would be recognised and protected.


We advocate that the new system for planning recognises that over 90% of heritage assets are undesignated, that they will not only be located in ‘protected’ zones, and that they usually rely primarily on processes for obtaining planning permission for their protection. Suitable and robust safeguards must be in place. Any approach that divides the land into three types of zone for planning needs to take account of specialist advice and use HERS and Historic Landscape Characterisation, as well as the MAGIC database to understand the environmental sensitivities of every place and so inform the management of development in all categories of development area.  Variances will also have to be made for certain issues, such as where designated sites such as scheduled monuments may fall within larger growth zones. There is no mention in the Government’s Planning White Paper of how listed building consent and applications affecting conservation areas, registered parks and gardens and battlefields will be dealt with outside protected areas. If the system still requires these consents, then they risk being seen as holding up development.


We support the proposed solutions from our member, the Chartered Institute for Archaeologists, that would work with the Government’s proposal for automatic outline consent in growth areas. For example, there must be a process for assessment of the historic environment by Local Planning Authorities which would involve putting Historic Environment Record (HER) datasets on a statutory footing. This would assist in data being available at the plan-making stage and ensure developers have the same baseline position. In addition, we would welcome the Government exploring with the heritage sector an increased number of zones or establishing careful sub-categories which align with international zoning systems.

We also support our member, World Heritage UK, in raising concerns about World Heritage Sites hardly being mentioned in the Planning White Paper. World Heritage Sites must have statutory recognition, alongside existing national heritage, environmental and landscape designations. The Government, as a State Party under the World Heritage Convention, has an obligation to the world to protect these premier heritage sites.  Furthermore, it is not clear in the White Paper how World Heritage Sites will be treated in a new planning system, and this matter needs to be clarified.

It is worth noting that what is considered heritage can change over time. For example, the Barbican complex in central London was not - at one time - considered as “heritage”, but now would clearly be considered an important part of our built heritage. There must be flexible protections for those buildings that become part of our heritage as time moves forward.  The historic environment is not a defined resource, more will be discovered and also buildings as they come of age or are recognised for their national heritage importance will get designated and therefore need to be taken into account on any site.


7. What changes, if any, are needed to the green belt?


A vital purpose of the planning system is to contribute to protecting and enhancing our natural, built and historic environment. However, the Government’s proposals in its Planning White Paper to introduce a zonal planning system would weaken protection of green space designated for ‘growth’ or ‘renewal’, and offer no additional safeguards for those earmarked for protection. ‘Protected’ areas as defined by the new proposals will be those with site designations such as Green Belt, Areas of Outstanding Natural Beauty (AONBs) and Conservation Areas, giving no consideration to the importance of undesignated green spaces near to where people live.


Government data shows that there has been a 62% increase in the loss of greenfield Green Belt land since 2013, with 315 hectares lost in 2016/17 alone. The National Government should develop clear guidance for local authorities on housing requirements to protect designated land, support the creation of new Green Belts where local authorities have established a clear need for them and ensure departments work together to direct economic and housing growth towards areas with capacity for redevelopment on brownfield sites.  This will protect a significant proportion of our nature reserves and our valuable natural heritage.



October 2020