Council for British Archaeology Response to Proposed Reforms to the National Planning Policy Framework and Other Changes to the Planning System
The Council for British Archaeology (CBA) is a charity committed to making archaeology accessible to anyone interested in exploring the stories of people and place. As the voice of archaeology in the UK we bring together community groups, commercial units, academics and heritage organisations to create and share opportunities to participate, discover and be inspired by archaeology.
As a national amenity society, the CBA are statutory notifyees within the planning system. We review over 4000 planning applications each year, 85% of which are for Listed Building Consent (LBC). Through our Listed Buildings Casework team and advocacy work we speak up for the historic environment. Our primary focus is around the archaeological and historic interest in the built environment and its appropriate conservation and reuse. Archaeological interest and evidential value lie both above and below ground, across our landscapes and settlement patterns. We believe that changes within the historic environment should be informed by an understanding of where significance lies in evidencing how places have evolved in relation to people over time. We champion the important contribution that the historic environment makes to the place-based identity and wellbeing of current and future generations. Adapting and reusing the historic environment and archaeological interest lies at the heart of our mission and values.
Summary
The Council for British Archaeology (CBA) welcomes many of the changes in the draft framework, have concerns about the potential impact of some reforms to policies and recommend a number of revisions to the consultation draft which we believe would better deliver the stated objective of the planning system, to deliver sustainable development. Our consultation response focuses on the intended and unintended consequences of the NPPF for management of the historic environment through the planning system.
We welcome the positive reframing of the contribution that the historic environment makes to people and places, including enhanced recognition of locally valued non-designated heritage and the role of local heritage lists. We also welcome the recognition in national planning policy of the public benefits (towards carbon reduction targets and local place making) that stem from the adaptive reuse of existing buildings and better use of vacant historic buildings. Clarification on the role of applicants in assessing significance and the impacts of development proposals on heritage assets is also welcomed.
We are concerned about the proposed framing of archaeology in the consultation draft and provide detailed advice on the need for, and means by which, this should be improved through revision. In this regard the CBA have collaborated with Historic England, the Chartered Institute of Archaeologists and the Association of Local Government Archaeological Officers to devise recommended revisions to draft policy for archaeology on behalf of the archaeological sector.
The CBA have identified multiple areas where the role of heritage at a strategic level, specifically in regard to Spatial Development Strategies, and across other policy areas should be explicitly referenced in national policy. We have also raised concerns about the impact on the historic environment which would result from a tilted decision making balance towards a presumption in favour of a wide range of proposal types that would undermine the environmental and social objectives of sustainable development as well as the plan-led system.
Responses to Questions
To view our responses to questions in detail, please download our full response letter below.
