Consultation responses: Protection of World Heritage Sites (DCMS2008)	Consultations index ALGAO:England
Submission from ALGAO:England 20th August 2008 The Role of ALGAO:England The Association of Local Government Archaeological Officers for England (ALGAO:England) is the national body representing local government archaeology services at County, District, Metropolitan, Unitary and National Park level in England. ALGAO:England co-ordinates the views of its member authorities (93 in total) and presents them to government and to other national organisations. The range of interests of our members embraces all aspects of the historic environment including archaeology, buildings and the historic landscape which is not designated. Clearly these comments will relate particularly to these aspects. On 27th May the government published a consultation paper inviting comment on three documents relating to the protection of World Heritage Sites in England; Draft Circular on World Heritage Sites, English Heritage's Draft Guidance Note on 'The Protection and Management of World Heritage Sites in England Proposed amendments to the 1995 General Permitted Development Order (GPDO)' THE DRAFT CIRCULAR The principal elements of the circular are; Reference to (and implied support for) the UNESCO 'Operational Guidelines for the Implementation of the World Heritage Convention 2005' and other relevant guidance. Reference to the critical test for the management of WHS, which is the protection of 'Outstanding Universal Value' (OUV) and the statement that this is to be treated as a 'key material consideration' in the planning process. A requirement for the management needs of a WHS to be taken into account in every aspect of the planning system. Guidance on the development, content and agreement of WHS Management Plans. The need to protect the setting of a WHS. The role of buffer zones is explained in this context. Call in procedures specifically for development proposals in WHS about which English Heritage have objected. These particular proposals have recently been the subject of a separate consultation. Comment The proposals are to be welcomed but the Association feels that they are less far reaching than they might sound. It is regrettable that 'call ins' of development proposals are to be limited to those objected to by English Heritage (EH) as there are cases where EH is either unable to comment, for want of resources or to object because of other potential constraints. The provision should be extended to include development proposals to which any of the statutory national amenity society consultees or ICOMOS UK has objected. For a number of WHSs conservation area designations are an important part of the planning management system. For example the Derwent Valley Mills World Heritage Site (DVMWHS) is made up of village and town centres containing a number of designated 'conservation areas'. These designations are an important part of the planning management system for the protection of the DVMWHS and yet because the designations are LOCAL designation (as opposed to national ones) the weighting of the designation, and thereby the protection it affords in the planning system, is less than for national designations, e.g. scheduled monuments or listed buildings. The Heritage Bill, and this circular which it supports, has not taken the opportunity to introduce a national designation of conservation areas, i.e. "areas of special architectural or historic interest the character of which it is desirable to preserve or enhance", deemed to be of national or international importance. This is most regrettable as it will leave the planning protection regime weak in this respect. The draft circular states " World Heritage Site Management Plans should be prepared on a participatory basis by a Steering Group or Committee made up of key stakeholders in each Site. These will vary according to the Site but should include parish councils, DCMS, English Heritage and other official bodies or NGOs with an interest in the site. The leader of the Group will also vary according to the nature of the site but is often the relevant local authority or the key owner of the site" A critically important issue which the draft circular does nothing to resolve is how local management Groups are to be sustainably resourced. The draft circular requires management Groups to be set up to fulfil the undertakings entered into by HM Government (as signatory to the World Heritage Convention) by managing World Heritage Sites on behalf of the Government, in accordance with UNESCO requirements. The draft circular however provides no indication how local management Groups are to be resourced. The level of need will vary from Site to Site but those which are in multiple ownership and which fall within a number of local authority areas require a full-time coordinator with some minimal administrative back up plus a small budget to facilitate adequate communication with stakeholders. The total cost of managing a Site will be well in excess of what is needed to meet these fundamental 'core management functions', and the cost of enhancement projects, educational and promotion projects, and other time limited projects can often be met from partnership funding but the funding to fulfil 'core management functions' should come from Government. It is also desirable for explicit provision to be made for the grant aiding of repair and enhancement projects in World Heritage Sites. To facilitate this it is suggested World Heritage Sites should be added to Section 155 of the Bill (155 (2) ) and Section 185, which relates to grant aiding powers. ENGLISH HERITAGE DRAFT GUIDANCE NOTE The principal elements of the note are A description of what a WHS is, how it is designated and how it should be managed. Conservation principles Guidelines for the content of a WHS Management Plan. Comment The note is largely a helpful description and explanation of the existing situation. An amplification of the part of the note dealing with the nature of 'Buffer Zones', to employ the language used in the UNESCO Operational Guidelines would be helpful. It is often not understood that buffer zones define the "immediate setting" of a WHS. Impacts upon WHS can also result from development beyond buffer zones, in the wider setting. The note explains that "It is essential to consider the impact of each development proposal upon the Outstanding Universal Value." The note should, in addition, explain that this test should apply to requests for Certificates of Immunity. REVISION OF THE GPDO The proposed revision of the GPDO would require the following, currently permitted development, to require planning permission; Extensions to dwellings of over 50 cubic metres or 10% of the cubic capacity of the dwelling. External cladding to dwellings Enlargement of dwellings by means of additions or alterations to roofs. Ancillary buildings in the curtilage of a dwelling. Installation of certain antenna on industrial or warehouse development. Extensions to industrial buildings or warehouses of over 500 sq metres or 10% of the floor space. Extensions to schools, colleges, universities and hospitals, normally permitted development (PD) shall not be PD unless the appearance of the building materials is similar in appearance to that of the main building. Comment The extension of limitations to permitted development within WHSs is to be welcomed but it is not as far reaching as it may sound. Extensive damage to the urban historic fabric within conservation areas can and is caused by incremental, unsympathetic alterations to doors and windows in unlisted dwellings and to the loss of historic roof coverings. Such changes can only be brought under control by the introduction of Article 4 Directions, which require substantial staff resources in terms of officer time, to introduce. Experience has shown that Local Planning Authorities often do not have adequate resources to undertake this to any great extent. Microgeneration schemes can also be potentially damaging in the context of a WHS and it is felt that such proposals within a WHS should be added to the list above also be required to have planning permission. David Barrett, for ALGAO:England Consultations index Planning & Legislation Committee DCMS Consultation document