The National Planning Policy Framework for England has now been underpinned by government guidance, following consultation on a draft last year (see IfA’s response here.
While much of the guidance is relevant, the most directly pertinent material is found at the planning portal website. With support from English Heritage, IfA and ALGAO:England worked hard to get some key messages absent from the NPPF into this government guidance, and against some resistance succeeded in getting a useful statements on HERs that captures their need to be maintained: Historic environment records are publicly-accessible and dynamic sources of information about the local historic environment. They provide core information for plan-making and designation decisions (such as information about designated and non-designated heritage assets, and information that helps predict the likelihood of current unrecorded assets being discovered during development) and will also assist in informing planning decisions by providing appropriate information about the historic environment to communities, owners and developers as set out in the National Planning Policy Framework.
Based on material provided by IfA and ALGAO, the section What are non-designated heritage assets of archaeological interest and how important are they? establishes that non-designated assets – about 95% of what archaeologists deal with – remain firmly within the remit of the planning process.
The National Planning Policy Framework identifies two categories of non-designated site of archaeological interest:
(1) Those that are demonstrably of equivalent significance to scheduled monuments and are therefore considered subject to the same policies as those for designated heritage assets (National Planning Policy Framework Paragraph 139). They are of three types:
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those that have yet to be formally assessed for designation
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those that have been assessed as being nationally important and therefore, capable of designation, but which the Secretary of State has exercised his discretion not to designate usually because they are given the appropriate level of protection under national planning policy
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those that are incapable of being designated by virtue of being outside the scope of the Ancient Monuments and Archaeological Areas Act 1979 because of their physical nature
The reason why many nationally important monuments are not scheduled is set out in the document Scheduled Monuments, published by the Department for Culture, Media and Sport (DCMS). Information on location and significance of such assets is found in the same way as for all heritage assets. Judging whether sites fall into this category may be assisted by reference to the criteria for scheduling monuments. Further information on scheduled monuments can be found on the Department for Culture, Media and Sport’s website.
(2) Other non-designated heritage assets of archaeological interest. By comparison this is a much larger category of lesser heritage significance, although still subject to the conservation objective. On occasion the understanding of a site may change following assessment and evaluation prior to a planning decision and move it from this category to the first.
Where an asset is thought to have archaeological interest, the potential knowledge which may be unlocked by investigation may be harmed even by minor disturbance, because the context in which archaeological evidence is found is crucial to furthering understanding.
Decision-taking regarding such assets requires a proportionate response by local planning authorities. Where an initial assessment indicates that the site on which development is proposed includes or has potential to include heritage assets with archaeological interest, applicants should be required to submit an appropriate desk-based assessment and, where necessary, a field evaluation. However, it is estimated following an initial assessment of archaeological interest only a small proportion – around 3 per cent – of all planning applications justify a requirement for detailed assessment.
There is encouragement to include non-designated assets in the Local Plan.
More detailed advice on good practice is being evolved by English Heritage and partners from the Historic Environment Forum (including IfA). Pending consultation on and completion of that document, the PPS5 Practice Guide remains in force – not an elegant solution and not a perfect document, but for the short term it serves as a safe enough underpinning of good practice with sufficient links to IfA standards.
