06 Oct 2022

The CBA expresses its concern over deregulation of planning for the government’s proposed “Investment Zones”

As part of the recent “mini-budget”, the government revealed their intention to allow local areas to host so-called “Investment Zones”. As part of this, they propose the deregulation of established planning procedures. The CBA are deeply concerned by this proposal and other proposed changes to environmental legislation – read on to find out why it is so important to maintain the link between archaeology and planning, the importance of sustainable development and how the CBA are taking action.

As was underlined during the directors’ article published British Archaeology in January 2021 (BA 176 – January/February 2021) “planning and archaeology have a mutually beneficial relationship. Both revolve around the connections between people and places”.

Indeed, since the establishment in 1990 of Planning Policy Guidance 16 (PPG16) the planning system has been a key mechanism in uncovering new archaeological finds and securing knowledge gains from archaeological discoveries. Developers have had clear processes to follow, and early archaeological assessment has helped development to proceed without last minute archaeological ‘surprises’ knocking a scheme off track in timetable and/or budget.

Upfront assessment of sites for natural and historical sensitivities has been extremely valuable in securing public benefits from development and thinking about what matters to people.  It’s almost unheard of for buried archaeology to preclude development. Instead, archaeological recording strategies have helped improve understanding of how local places have developed in the past and how people have lived there before us. The benefits of understanding places are clear, in establishing meaning for those who live there now, creating a sense of belonging and pride of place, and thus contributing to wellbeing.

So has this consideration and understanding of the natural and historical sensitivities of development sites been forgotten in the creation of the government’s proposed “Investment Zones”. With so little detail it’s hard to say for certain at this time but a driving criterion for Investment Zones is speed of delivery. It is intended that these zones will “Accelerate the housing and infrastructure the UK needs to drive economic growth.” To achieve this the government propose to “cut back unnecessary bureaucratic requirements and processes and red tape that slow down development.” What exactly that red tape is not clear but the wider message from government is clear – it will be environmental protections which are cut.


The CBA are deeply concerned that the proposed planning deregulation will bypass the existing, successful, processes that ensure potential impacts from development to the historic and natural environment are understood in advance, and then minimised and mitigated against. Viewing this as red tape that slows the process down is superficial and erroneous. PPG 16 was borne out of the surprise discovery of Shakespeare’s Globe Theatre during development work in London. Nothing throws the timetable and budget of a project out like that kind of discovery. Large developments requiring upfront assessment is the product of experience!

We know that important archaeology, of equal importance to known designated archaeological sites, is sleeping quietly across the country. Often it is only when a site is proposed for development that its archaeological potential is fully assessed and understood. This is development-led archaeology, which takes place within the planning process and it is not yet clear the extent to which existing guidance will be overridden. Despite mention in the recently-published call for Expressions of Interest that heritage will be considered in the creation of Investment Zones, its unclear the extent to which undesignated heritage assets and landscapes will be taken into account, nor how Investment Zones would be managed in sensitive landscapes like AONBs and National Parks.

As such, the CBA’s current role is one of gaining understanding. We are working with our advocacy partners to understand the true implications of these plans for our historic environment. These partners include the Chartered Institute for Archaeologists, Association of Local Government Archaeological Officers, The Archaeology Forum, Federation of Archaeological Managers and Employers, the Joint Committee of National Amenity Societies, The Heritage Alliance, The National Trust, Countryside and Wildlife Link and the Council for the Protection of Rural England, to name a few.

The relationship between the historic environment and the natural environment makes them inextricably linked, especially in rural areas. As a result, the CBA collaborate with a number of advocacy groups for the natural environment and have added our voice to call out the threat these plans pose to nature, biodiversity and climate action. We fully support the current campaigns #AttackOnNature and #PeoplesPlanForNature.

We will continue to take part in conversations to share understanding, thinking and resources, and make sure our collective voice is heard. This includes joining forces with other organisations to make clear our deep concerns about the plans: we are amongst the 78 signatories of the Wildlife and Countryside Links’ recent open letter to the Prime Minister, as well as the #BetterPlanningComission’s letter to levelling up secretary, Simon Clarke, urging the government to rethink their deregulatory approach to planning reforms. This collaborative approach is a key part of our advocacy work, and helps us make the most of our limited resources. Everyone can help in this essential work by contacting their own MPs and the Government to set out their concerns and call for continued support of wider environmental protection.

Bamburgh Research Project.jpeg
© Image credit: Bamburgh Research Project

As we continue to learn more about the governments proposals for Investment Zones and planning deregulation – the CBA will assess the implications of the plans on the historic environment and take appropriate action as needed.

It is critical that the selection and creation of Investment Zones is informed by a proper understanding of what’s there and what matters for our environment and the wellbeing of local people. A myopic focus on ‘contribution to growth’ along with potential speed of delivery risks overlooking the contribution of heritage and nature to the delivery of public benefits. What is more, our economy and society are dependent on a healthy and thriving environment. It is the bedrock of creating places where people want to live and work. Creating sustainable places is key to meeting net zero imperatives. The CBA will continue to advocate for archaeology, alongside and in support of our partners, but remember that you too can add your voice to the support archaeology, heritage and the environment.

One simple step you can take is to write a letter to your MP; you can find some helpful guidance on how to do this in our toolkit here.

Want to support the CBA’s advocacy work? Find out more here.