RESCUE

The British Archaeological Trust

15a Bull Plain, Hertford,

Hertfordshire SG14 1DX
Telephone: 01992-553377

rescue@rescue-archaeology.freeserve.co.uk
http://www.rescue-archaeology.org.uk

National Planning Policy Framework:

Comments by RESCUE: the British Archaeological Trust

RESCUE is an entirely independent charity, which exists to promote and highlight the
interests of archaeology and the historic environment within the United Kingdom. We have no links
with any political party and are funded entirely by the subscriptions and donations of our members.
Details of our activities can be found on our website: www.rescue-archaeology.org.uk. Please note
that this communication and any response we may receive as a consequence will be placed on our
website for the information of our members.

The Government has stated that the aim of this exercise is to consolidate policy statements
into a single National Planning Policy Framework. This is intended to be localist in approach, used
as a mechanism for delivering the Government’s objectives only where necessary, proportionate
and effective to do so, and will be user-friendly and accessible, providing clear policies for making
robust decisions. The Government has also stated that it will continue to maintain environmental
designations which protect the character of our country’s landscape, and stop unsustainable urban
sprawl.

With reference to archaeology and the historic environment we would like to stress that there
already exists a policy document which addresses these aims. Planning Policy Statement 5 –
Planning for the Historic Environment, was only introduced in March 2010. The policies it contains
allow for the assessment, investigation, protection and mitigation of development impacts upon
Heritage Features where they are affected by proposals. This is a principle of development pre-
commencement work that has been accepted by the construction industry since 1990 with the
publication of PPG16 and1994 with the publication of PPG15. PPS5 continues a regime of heritage
protection within the planning process that is firmly embedded and successfully implemented by all
interested parties. We are strongly of the opinion that this document which is extremely recent, up-
to-date and modern in its approach, and which has been broadly welcomed by the development and
historic environment sectors combined, should be defended during this review and should remain
in place within any new framework.

In addition to the above recommendation and bearing the stated aims of the Government in
mind, we would also like to suggest ways in which the heritage and planning management system
embodied in PPS5 could be enhanced as a result of this review.

It is unfortunately the case that the successful implementation of heritage protection regimes
is dependant upon a very small number of specialist posts within Local Authorities. For a number of
years these posts have dwindled, as successive reviews have focussed upon the vulnerable non-
statutory status of heritage protection within the planning process and reduced capacity accordingly.
It is now the case that the very fabric of the country’s historic environment is threatened with real
damage and loss, due to the under-resourcing at local levels. With the Government having quite
clearly stated that it is at the local level where decision-making should take place, we strongly urge
that heritage protection services within Local Planning Authorities should be afforded statutory
status as a result of this review. Only through such a measure could the Government be assured
that local communities would have the authority to exercise the appropriate control over their
environment, enabling them to identify, highlight and protect from destruction, any and all elements
of heritage interest that they consider of worth.

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 We would also recommend that the Government should address the lack of adequate
consideration within the current planning process afforded to as yet unclassified or undiscovered
Heritage Features. With particular reference to archaeology – although the principle can also be
extended to battlefields, historic parks and gardens, and wider landscapes – it is important that
there is provision within the system for early assessment within areas of potential importance. At the
moment, the provision only exists where previous investigation or chance discovery has indicated
that remains or sites of significance are present. However it is clearly demonstrable that large areas
of the country have not been subject to dedicated survey from the historic environment perspective,
and that these areas have the potential to contain information of significant importance.
(examples?). There must be a reasonable policy provision within the planning process to take
account of this probability. Where independent expert advice indicates such a risk, there should be
a policy within the system to allow for early assessment of undesignated sites for the presence of
hitherto undiscovered or unrecognised archaeological material or features of heritage significance.
Once again, such a policy provision would empower local communities to identify sites and features
within their own area, and make provision for their protection from damage during any subsequent
development process.

RESCUE: January 2011

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