English Heritage believes that if a small number of changes and additions to the National Planning Policy Framework (NPPF) are introduced, the protection of the historic environment can be maintained at the existing level, which is the stated aim of Government.
Our main concerns are:
- The wording of the historic environment policies section and the wording of the presumption in favour of sustainable development sections need to be reconciled so that there is no confusion in interpretation, leading to an unintended reduction in the level of protection for the historic environment.
- The lack of a policy to deal with proposals causing moderate or minor harm to heritage assets.
- Inadequate protection of undesignated but nationally import archaeology in areas where there is a Neighbourhood Development Order.
- Inadequate recognition of the positive contribution the historic environment can make to sustainable development. We would like to see a policy that encourages the viable use of heritage assets, where possible, and to see recognition that the historic environment has a positive role in making characterful and sustainable places.
- That the protection of our nationally important historic buildings and sites should be given ‘great weight’, to be consistent with the wording for the protection of National Parks and Areas of Outstanding Beauty.English Heritage believes that all the above concerns can be addressed through a small number of changes or additions to the text and we have made these suggestions in our consultation response.