Following a six month campaign (Save Britain’s Historic Landscape), starting in August 2011, shortly after the publication of the draft NPPF – Spear’s Editor-in-Chief William Cash has compiled detailed evidence suggesting that the draft NPPF does not – despite repeated assurances by the DCLG – give adequate protection to ‘heritage assets’, in particular those heritage tourism assets which contribute directly (£7.1 billion directly) to economic growth and the economy through jobs, employment and attracting visitors and trade investment to the UK. The campaign’s main Spear’s leaders, articles and blogs are provided in the Appendix to this submission.
This submission has been compiled through five months of research into planning applications (and recent planning Inspectorate Decisions) across the country that have implications for heritage. William Cash has also consulted with various leading UK heritage bodies including English Heritage, the Heritage Alliance (chaired by Loyd Grossman, and the umbrella organisation for almost 100 UK heritage groups), as well as the National Trust, Historic Houses Association (HHA) and the Country Land and Business Association (CLA).
Based on such consultations, this submission reflects the views of William Cash who is also a member of the HHA, CLA, National Trust and English Heritage in a personal capacity. One reason, indeed, for writing this submission is that despite sharing many common interests and concerns , the heritage lobby sector is not by any means a united front on all issues. Through being an individual member of all the above heritage organisations – and attending various AGMs – William Cash has been independently positioned over the last six months to hear all the arguments put forward by all sides, including the government itself.
For example, at the HHA’s AGM at the Queen Elizabeth Conference Centre in November, Heritage and Tourism minister John Penrose unambiguously stated in his key-note address to the 1500 members of the HHA (whose members have more combined heritage properties than the National Trust and English Heritage) that the government was ‘fully committed to protecting heritage’ in the NPPF. This submission is an attempt to look objectively at all the various arguments as well as trying to suggest some original proposals and revisions to the NPPF that improve and enhance the current draft leading to the right sort of development that results in more and better housing as well as long-term UK growth.
Yes, the planning system urgently needs reform but good planning must aim to get the balance right between heritage, housing needs and the environment. With a de facto ‘yes’ to development, such balance has been removed from the planning system. To regain the balance this country so richly deserves, to protect our heritage, and to keep Britain GREAT – with heritage tourism and the historic environment being a critical platform for economic growth – we urgently need clarity from the revised NPPF.
The re-drafting of the NPPF is an opportunity to restore balance in the planning system. Since August 2001, when Spear’s launched our Save Britain’s Historic Landscape campaign, we have been at the forefront of this national debate.
We began our campaign by highlighting the tiny village of Winwick in Northamptonshire — population 70 — which is threatened with an invasion of wind turbines that will ruin the historic setting around the 15th-century manor, which was once owned by Sir Thomas Malory. A month later, the BBC’s Newsnight cameras descended on the village and highlighted the problem that while 100 per cent of the village community are opposed to the planning development, a series of planning inspectorate Decisions seem to be overturning local government and local community wishes.
There is concern about this contradiction, not least in terms of the protection to the UK’s ‘heritage assets’. There is concern in the heritage sector that the current ‘protection’ has been much watered down in the draft NPPF. Whereas PPS-5 had ‘the presumption in favour of conservation’, the NPPF says that ‘considerable importance and weight should be given to [heritage assets’] conservation’, a lesser protection.
There needs to be closer regard paid to the significance of those protected heritage assets — listed buildings or scheduled monuments, sites of special scientific interest, archaeological sites, protected wreck sites, registered parks and gardens, battlefields — that directly bring in tourism, benefit the local economy and promote growth and local employment. This includes removing the de facto ‘yes’ presumption in favour of development for historic properties, affecting not just the National Trust and English Heritage but also 1,500 members of the Historic Houses Association.
In other words, there should be extra consideration given to heritage assets that help to stimulate the local economy, whether they are open to the public or offering accommodation, conference facilities or other services. There should be special designation for the historic setting of buildings of national importance that are part of the heritage tourism of the UK, one of the few sectors that is currently experiencing growth (and will do so even more next year thanks to the Queen’s Diamond Jubilee celebrations).
For some years English Heritage, under Simon Thurley, have pushed for heritage protection reform. This is urgently needed as the existing national list is largely based on an out-of-date system with much of the information from photographs and site visits from the Fifties and Sixties. Unfortunately, the Heritage Protection Bill that was put forward to offer better protection has been postponed as it was thought a hindrance to economic growth.
Yet this misses an even more important point: the existing draft National Planning Policy Framework is actually a potential brake on economic growth as it will damage heritage tourism, which currently brings in £24.1 billion a year to British economy.
This is why our heritage needs to be protected and why David Cameron is right to be spending £39 million promoting heritage as a crucial plank of his ‘Britain Is Great’ campaign, to highlight what makes Britain so special for foreign investment and tourists. Spear’s argues in this submission that we need to keep Britain great by safeguarding our unique heritage in the NPPF.
Recommendation 1: give some tightened designated heritage protection in the NPPF to ‘heritage tourism’ assets of significance that directly contribute to sustainable economic growth.
The total number of mainstream ‘heritage tourism’ properties in the UK open to the public amounts to approx just 1100 properties in total (National Trust around 350), (English Heritage around 400) and HHA (core of around 350). These 1100 heritage properties play a critical role in contributing £12.1 billion to the UK economy, with ‘heritage tourism – according to English Heritage currently growing at 2.6% per year – one of the few areas of the economy that is growing – more than manufacturing.
There are approx 400,000 listed buildings on the National Heritage List. These 1100 properties – across the country – amount to just 0.25 % of all listed buildings. Yet these important ‘heritage assets’ play a critical role in the tourist economy and sustainable economic growth. With the formal removal of PPS5 from the NPPF, which provided a ‘presumption in favour of conservation’ for such ‘heritage assets’, there is a strong case for some special designation in the NPPF to protect these 0.25% of heritage buildings.
Recommendation 2: The case for a review of the current listing system under the new National Heritage List and tightening the statutory protection given to Grade 1 or Grade 2* buildings of national significance. Currently only 2.5% of approx 400,000 listed buildings are Grade 1.
Yet the protection – especially in regards to the ‘historic setting’ – of such Grade buildings receive under the NPPF (with PPS 5 removed) is a cause for concern as developers simply pay so-called ‘heritage consultants’ to do desk top cultural heritage surveys from their desks that are simply designed to diminish and degrade the cultural significance of so many Grade 1 buildings of universally acknowledged architectural and historic importance – such as Grade 1 Kimbolton Castle, by Vanbrugh, which has four Grade 1 facades and was the former palace of Catherine of Aragon. Yet the Scottish ‘heritage’ expert who was delivered by the developers Broadenergy at the Kimbolton Castle public inquiry (which ended on January 23) told the inspector that having wind farms behind the castle amounted to ‘moderate’ cultural impact.
Recommendation 3: give more specific clarity in term of wind turbine positioning and national heritage assets. As our Spear’s leader launching our campaign argues, the current draft of the NPPF does not give either local councils or inspectors the sort of clarity as to what is an ‘appropriate’ location for a wind farm and what is not, especially in terms of important ‘heritage assets’. More clarity about where wind farms can be sited in proximity to important ‘heritage tourism’ assets would be very welcome.
Several suggested amendments (enclosed at end of Section 3) have been scrutinised (and passed onto the Prime Minister on January 2012) by Chris Heaton-Harris MP, who is chairman of a new cross-party Parliamentary group of a growing number of MPs (over 90 at the time of submission) who are seriously concerned about the ‘direction of traffic’ – to use the Planning Inspectorate’s own phrase in its advice to its inspectors in interpreting the draft NPPF – on the matter of wind farms, NPPF and Localism Bill.
Spear’s supports the case for Heritage Protection Reform as proposed by English Heritage and the Heritage Protection Reform Bill, which has been postponed. Were such a bill to be re-introduced it could help give critical clarity for both developers, planners, councils and inspectors and save millions each year with exhaustive and expensive public enquiries across the country that only serve to divide communities, create political anger, undermine the Localism Bill.
Whilst we realise that the chances of resurrecting the Heritage Reform Bill in the current economic climate are remote, looking at the above other measures outlined (1-3) would go a long way to ensuring that protecting heritage tourism is properly considered within the NPPF.