Implications for Archaeology and Heritage in the Draft NPPF

The government is currently consulting on the biggest raft of changes to national planning policy since the National Planning Policy Framework (NPPF) was first introduced in 2012. This comes hot on the heels of the Planning and Infrastructure Act receiving Royal Assent. The much-anticipated NPPF revision draft further supports aims to unlock and streamline the delivery of new homes through overhauls to the planning system.

Why does this matter? Our heritage is primarily managed through the planning system. National policies for the historic environment (within the NPPF) establish the criteria for managing change to it. The majority of archaeology undertaken across the country is development-led. So, significant revisions to the national planning policy rulebook have important repercussions for heritage with archaeological interest, above and below ground. We are clear: archaeology is not a blocker to development, but it must be managed in a way that avoids unnecessary harm to our archaeological record. Moreover, we should maximise opportunities to enhance the delivery of public benefits from development when archaeological mitigation strategies are required as part of a scheme.

As part of our advocacy work, the CBA will be responding in detail to the consultation. In the meantime, we are working closely with partners within the heritage sector, especially other archaeological bodies, to advise the Ministry of Housing, Communities and Local Government (MHCLG) on potential revisions to policies for heritage assets with archaeological interest.

Welcome Policy Changes

There are some positive changes which we welcome and have long championed:

• We are pleased to see revisions we have long advocated for, including a rehash of policies requiring the significance of heritage assets to be assessed, and the impact of proposals on that significance to inform planned changes to heritage assets. The current onus for assessing impact on planning officers has meant a high proportion of applications do not minimise levels of harm as part of initial proposals. This is a long-held bugbear of our listed building caseworkers, which often results in the need for revisions. We hope the clear requirement of an impact assessment as part of proposals will result in better-quality applications in their initial iteration. This should speed up the decision-making process. Better for everyone!
• We welcome direct reference to Local Heritage Lists as an important adjunct to Local Plans, as well as decision-making policies that support the adaptive reuse of buildings and their materials. We know and often flag that undesignated buildings can make important contributions to a local sense of place. Their adaptive reuse minimises wasting embodied carbon in their materials (contributing towards net zero imperatives), as well as maintaining and reinvigorating local identity—so valuable for regeneration and pride in place strategies, as well as retaining the archaeological interest of adapted sites.

Areas for Concern and the Need for Amendments

• We are concerned about the way in which policies for ‘archaeological assets’ have been separated out from other heritage assets. For a start, the implication in Policy HE10 that an ‘archaeological asset’ is ‘buried stuff’ overlooks the archaeological interest found in multi-phased buildings, urban grain, rural landscapes, etc. Heritage assets have archaeological interest when they hold physical evidence left by people in the past, which helps us understand how previous generations have adapted and changed places to meet changes in needs and aspirations. Heritage assets with archaeological interest are everywhere, and central to the character and identity of places.
• We also view the proposed policy HE10.2 as a missed opportunity to enable archaeological investigation to deliver the breadth of public benefits it is so capable of. To achieve wider forms of public benefit outcomes from development-led archaeology, there needs to be a hook within national planning policy. The draft policy requires archaeological mitigation strategies to include provision for the “investigation, understanding, recording, dissemination and archiving of that asset.” Adding “and activities to provide public benefit” would open the door to a raft of activity with social value, unleashing archaeology’s superpower to make connections—supporting the relationship between people and their places, developing social cohesion, and enacting place-shaping agendas. Scotland already has this in national policy—it can be done. The equivalent policy in Scotland’s NPF4 is supported by ALGAO’s excellent guidance: Delivery of Public Benefit and Social Value, Guidance for Archaeology in the Planning Process. This is the moment to urge the Westminster government for the same provision in England, which we strongly encourage our members and supporters to do.

Other policies outside the heritage-specific chapter will have implications for how the historic environment is managed. The increased move towards a plan-led system, with the intention to speed up the decision-making process, means information, at an appropriate level of granularity, needs to be assembled up front at the plan-making stage. This relies on sufficient data being collated to inform spatial strategies and site allocations.

We believe that making Historic Environment Records (HERs) statutory is an important component of the necessary geospatial data set. Placing HERs on a statutory footing requires secondary legislation to enact this component of the Levelling Up and Regeneration Act. We are advocating this to be necessary and timely. With the development of Strategic Development Strategies and a ‘default yes’ to development in grey belt, brownfield, and sites near stations, awareness of any sensitivities and opportunities in specific locations will be important to ensuring the certainty for developers, and clarity around the likelihood mitigation strategies will be needed, that the government is looking to achieve.

The draft NPPF document is open for public consultation until 10th March. We urge our members and supporters to take this opportunity to have your say. If you, like us, believe the public benefits from archaeology should be opened up to encourage better public engagement, as well as knowledge gain and the development of research agendas, then be sure to include an answer to Question 190 in your response.

If you would like to discuss the NPPF consultation with us and hear more about the CBA’s advocacy work around this consultation, you can join us for an evening session on 26th February from 7:00 PM – 8:00 PM. Neil Redfern (Executive Director) and Catherine Bell (Listed Building Casework & Advocacy Manager) will be presenting information around the topic and be available to answer your questions.