World Heritage UK responds to draft National Planning Framework

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WORLD HERITAGE UK’S RESPONSE TO DRAFT REVISED NATIONAL PLANNING FRAMEWORK FOR ENGLAND

 

cityscape St Pauls and The Shard

The Government’s planning policies for England are set out in the National Planning Policy Framework (NPPF).  The Government has recently announced its intention to revise the Framework and has consulted on a draft revision.  World Heritage UK (WH:UK) responded to the consultation.

As a State Party to the World Heritage Convention, the United Kingdom is required to protect, preserve, present and transmit to future generations its World Heritage Sites.  It does this primarily through its planning systems. In the last 18 months, WH:UK has been working to suggest how the UK’s planning systems could be improved further to meet these responsibilities.   It based its response to the Draft Revised National Planning Policy Framework largely on this work.

In its response, WH:UK pointed out that England’s World Heritage Sites include a wide range of historic monuments and past industry, landscapes, townscapes, and natural and ecological features.  Therefore they will be affected by many of the policies in the NPPF. They cannot be treated as a single homogenous entity.

The full text of WH:UK’s response can be found under Correspondence and Consultations on its website Response to draft NPPF May 18 – resubmission final.

The key points in WH:UK’s response are:

  • Recognition.  WH:UK welcomes the recognition given to the protection of World Heritage Sites in various places in the Draft Revised NPPF.  It urges that, in due course, such protection should be enshrined in primary legislation.
  • Development Plans. WHUK strongly disagrees with the proposed changes to the nature of the “development plan”.   The Draft Revised NPPF states that, while local planning authorities will be obliged to produce a plan that addresses the strategic priorities for their area, there would be no obligation on them to produce more detailed policies in a Local Plan.   However Local Plans contain the very policies that currently protect, preserve and help present World Heritage Sites. They cover issues such as good design, the type of development that is or is not acceptable at or adjacent to World Heritage Sites, the protection of Sites’ settings and/ro buffer zones and the promotion of conservation.   It cannot be assumed that local authorities will voluntarily produce local plans. If they do not, this would severely weaken the effectiveness of the planning system in helping to deliver the State Party’s obligations on World Heritage Sites.
  • Pre-application engagement. WH:UK welcomes the continuing support for pre-application engagement.  It has encouraged its members to be more actively involved in decision-making processes and recognises the value of early dialogue.
  • Economic value of World Heritage Sites. WH:UK suggested that the NPPF should recognise the economic value of World Heritage Sites both locally and nationally.
  • Good design. WH:UK strongly supports the encouragement of good design.  It does not agree that it would be acceptable for increased densities to overrule local character and history, including the surrounding built environment and landscape setting.  Such an approach could threaten the Outstanding Universal Value of a World Heritage Site or its setting and/or buffer zone, all as interpreted by policies in the respective local plan or plans.
  • Green Belt. Similarly, while WH:UK understands the need to make best use of urban land and to protect the Green Belt, it is important to appreciate that this policy approach can threaten the Outstanding Universal Value and/or setting/buffer zone of some World Heritage Sites by increasing development pressures within urban areas.    This is a question of priorities, which the Revised Draft NPPF does not resolve. Instead it states that development in Green Belts may be approved in “very special circumstances” while “Substantial harm or loss of …World Heritage Sites should be wholly exceptional.” WH:UK believes that, given their worldwide importance, World Heritage Sites should take precedence over Green Belts, and therefore there may be circumstances where it would be appropriate to review Green Belt boundaries to relieve development pressures at or adjacent to World Heritage Sites.
  • Natural World Heritage Sites.  WH:UK is seriously disappointed that the chapter on conserving and enhancing the natural environment does not recognise or set out policies for England’s natural World Heritage Site (the Dorset and East Devon Coast) or any such sites that may be inscribed in the future. The existence of such sites is recognised only in a footnote in the chapter on conserving and enhancing the historic environment, and then no indication is given as to whether the policies applicable to World Heritage Sites in that chapter apply to natural sites.  Nevertheless, WH:UK warmly welcomes the new reference in the first paragraph of that chapter to World Heritage Sites, which provides a clear signal in respect of the Sites’ importance.
  • Heritage Impact Assessments. WH:UK  strongly encourages the use of Heritage Impact Assessments to help local planning authorities determine development proposals, and considers these should be mentioned in the NPPF.
  • Development within World Heritage Sites. WH:UK supports of the proposed retention of the requirement on local authorities to “look for opportunities for new development within World Heritage Sites…to enhance or better reveal their significance;” while recognizing that not all elements of a World Heritage Site will necessarily contribute to its significance.
  • Minerals development. World Heritage UK welcomes the continued protection of World Heritage Sites through the provision of landbanks of non-energy minerals from outside these areas as far as is practical.  However that protection should also be applied to areas that form part of the setting and /or the buffer zone of Sites, as interpreted by policies in the respective local plan or plans.  Also the text addressing the issues on oil, gas and coal exploration and extraction is very weak in relation to heritage issues. In this respect, WH:UK advocates a similar approach as for non-energy minerals.

Author credit: Donald Gobbett, World Heritage UK Board Member

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