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

Edinburgh Management Plan consultation now open

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Old and New Towns of Edinburgh

Consultation is now open for feedback on the Old and New Towns of Edinburgh World Heritage Site Management Plan (2017-2022).

During the summer last year, over 1000 people took part in a consultation and gave us their views on how they felt the World Heritage Site is being run. What people told us has shaped the draft Management Plan. The draft Plan sets out a number of actions which will be taken forward by the management partners (City of Edinburgh Council, Historic Environment Scotland and Edinburgh World Heritage).

The consultation will run until 5 June 2017. Please take a moment to share your thoughts, ideas and suggestions using our online survey. You can also download the survey and send comments to worldheritage@edinburgh.gov.uk

Thank you very much for your help,

Chloe

Chloe Porter |Planning Officer| Planning Initiatives|Planning and Transport|Place|

The City of Edinburgh Council |Waverley Court, Level G3, 4 East Market Street, Edinburgh, EH8 8BG| Tel 0131 529 6235 | chloe.porter@edinburgh.gov.uk | http://www.edinburgh.gov.uk

World Heritage in Edinburgh

Culture White paper – your input needed

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We have rather belatedly caught up with the Culture White Paper process, and although the consultation seems to have been mainly in 2015, we have been assured by DCMS that as long as we get a letter to Ed Vaizey by the 3rd week of Feb, our views will be included.

There is little clarity as to what the White Paper actually is. It seems to be more of a discussion, prior to a document, which is in itself no bad thing, and is set out around the following 4 themes:

1)    Places: how culture helps to create places that are attractive and vibrant and how we will support places that want to use culture to drive development and regeneration. This section will cover how heritage is protected, managed, and made accessible; the diversity of heritage; heritage’s contribution to the economy and general wellbeing and the benefits of strategic investment in heritage.

2)    People: how culture benefits people in their individual and everyday lives, how we will improve access and participation, and use culture in wider social agendas, such as education, health and well-being. This section will cover heritage participation; heritage education programmes; the sector’s digital offer; and heritage crime.

3)    Funding: how government will help and support cultural organisations to increase philanthropy and access funding from new sources, and reform public bodies to ensure they are fit for the future. This section will cover Heritage at Risk; grant schemes; the role of the HLF, new ways of working and opportunities for philanthropy.

4)    Cultural Diplomacy: how culture contributes to the UK’s international reputation and soft power and how we will build on the current position to ensure that culture continues to support and contribute to our trade, exports and influence. This section will cover world heritage sites; underwater cultural heritage; the promotion of the value of cultural heritage; Britain’s heritage in the media; the protection of cultural heritage in the event of armed conflict and Illicit trade.

Whilst we (WH:UK) tried to get a place at a round table at the back end of 2015, this was not possible, and in fact most comments seemed to be invited through twitter and their blog. You can find more details at:

http://dcmsblog.uk/2015/09/share-your-ideas-for-a-new-cultural-programme/

http://www.theheritagealliance.org.uk/update/dcms-culture-white-paper-whats-in-it-for-heritage/

and a cursory google search (other search engines are available) will produce submissions etc.

So in order for WH:UK to write a meaningful letter, we need your input, and unfortunately, we need it quickly. If you are able, please could you write succint comments about the role that World Heritage Sites (as opposed to, but linked with, the whole heritage sector) can play in the four themes above. We will then distill this into something appropriate for a ministerial letter.

Please send your submissions to chris.mahon@worldheritageuk.org and the deadline is the end of next Monday (8th) please.

Many thanks

Sam Rose
World Heritage UK
Chair of Trustees