Consultation responses: Planning Policy Statement 4 (DCLG 2008)	Consultations index Planning and Legislation Committee Buildings Committee
Submission from ALGAO Historic Buildings Committee CONSULTATION PAPER ON DRAFT PLANNING POLICY STATEMENT 4 (PPS4): PLANNING FOR SUSTAINABLE ECONOMIC DEVELOPMENT Thank you for your consultation on the above. The following represents comments submitted on behalf of the Association of Local Government Archaeological Officers (ALGAO) through its' Historic Buildings Committee, that I convene. New Government guidance (when it is finalised) in terms of economic/employment land use can be welcomed in that the existing PPG4 Industrial, Commercial Development and Small Firms is now dated in respect of the major progress that has been made in Heritage Protection Reform since its publication. The Governments pledge to put the Historic Environment at the heart of a reformed Planning System must clearly now be translated through so as to be reflected in all relevant government guidance. As a general comment draft PPS4 clearly gives considerable weight in planning terms towards taking account of economic factors (market information, economic data, price signals, etc) - in the wider sense, it needs to be guarded against that economic factors are not given primacy over environmental and social ones. ALGAO wishes to stress that archaeological remains and the historic environment generally (as may be defined through Historic Landscape Characterisation) as well as individual historic assets need proper consideration in planning the delivery of economic regeneration and any potentially negative impacts need to be mitigated or avoided. It is acknowledged that such is briefly alluded to in paragraph 12 but the text could in our opinion benefit from strengthening to give greater clarity and emphasis to this aspect. That said, it is encouraging to note that draft PPS4 recognises in paragraph 25 and elsewhere (eg in Part 3 at paragraph 28) that individual historic buildings (whether formally designated or not) need to be seen as a resource and an opportunity for regeneration rather than a problem. The draft signals that the importance of historic assets resides inter alia in terms of area regeneration, wider economic benefit, historic value, and as being previously developed urban land through reducing pressure on greenfield sites. The retention and conversion of historic buildings for new uses is also acknowledged as being intrinsically sustainable through thereby reducing demolition and construction waste. ALGAO very much agrees with all of the preceding analysis since our direct experience suggests that historic assets of all types and including archaeological remains can often add real value to Regeneration Projects, particularly if this key aspect is appraised, properly understood and accommodated within scheme planning at the outset. Our experience also suggests that this timely approach is critical to the avoidance of unexpected costs and delays that might otherwise arise in the later stages of the regeneration process. ALGAO's responses to the questions in Part 4 of your consultation paper are limited to those that relate directly to the historic environment as set out below: 1. Do the policies set out in draft Planning Policy Statement on Economic Development achieve the right balance between economic, social and environmental considerations? Will they help to deliver sustainable development? Yes. Comment: In that the acknowledged importance of the historic environment and of individual historic assets will provide a platform on which to build proper consideration of the same into regeneration planning and that ought to lead to individual developments that are sustainable. 2. The draft Planning Policy Statement proposes a stronger emphasis on the need for evidence, including economic evidence for plan making and decision making. Do you agree that this is the correct approach? Yes/No Comment: Clearly this particular evidence base is envisaged in purely economic terms and ALGAO considers it important to note that a strong environmental evidence base is equally required in order to provide the real world context within which the effects of economic trends are bound to impact. 3. If you agree that there should be a stronger emphasis on the need for evidence what are your views on the following: The need for final Planning Policy Statement to include a suggested list of data as at Annex A? Are there any data/forecasts that should be excluded or added to the proposed list? Could the proposed data and forecasts also help to form part of the proposed new economic assessment that, subject to separate consultation, Local Authorities would be required to carry out? What is the most appropriate level at which data should best be collected: regional, sub-regional or local level? 4. Is there a need for separate planning policy guidance on the use of Simplified Planning Zones as set out in Planning Policy Guidance note 5? Yes Comment: From an ALGAO perspective the effective management of the archaeological resource normally relies upon the process set out in PPG 16 and therefore usually proceeds through a number of consecutive stages. Desk top site assessment/appraisal is often followed by physical evaluation so that the presence or absence of archaeological remains can be established with the significance of surviving remains then also being judged. This is in order to gauge a suitable response to individual development proposals and to the destructive impact that they may have. Suitable mitigation measures can then be discussed from a position of knowledge with the objective of both enabling the development and protecting significant archaeological remains. However, there will inevitably be circumstances where the demonstrable importance of archaeological remains outweighs the need for damaging development. Simplified Planning Zones would appear to confer a general presumption in favour of development without allowing proper consideration as to the potential impact of individual developments on archaeological remains. This is a departure from established environmental policy that ALGAO views as being entirely regressive. 5. Do you agree that the methodology used to determine sub-regional housing markets provide an appropriate proxy for determining economic markets? Yes/No 6. Is the approach to the location and development of B1 offices suitably flexible to meet the needs of business, whilst delivering sustainable development? Yes/No 7. Is the less prescriptive approach to non-residential car parking suitably responsive to the needs of business in the context of the objectives in Paragraph 4 of PPG13 Transport? Yes/No 8. Do you agree that employment sites should not be retained as such if there is no reasonable prospect of them coming forward for development during the plan period? Yes/No 9. Does this draft Planning Policy Statement deal adequately with the particular needs of rural areas? Yes/No Comment 10. Will this draft Planning Policy Statement have an impact upon the "equality strands", and particularly on the Gender, Race and Disability strands? If not, should it? We particularly welcome the views of organisations and individuals with specific expertise in these areas. Yes/No Comment Yours sincerely, Pete Boland Convenor, ALGAO Historic Buildings Committee. Consultations index Historic Buildings Committee Planning and Legislation Committee