PPS15: Planning for the Historic Environment has been published for consultation by the DCLG. The document seeks to replace both PPG 15: Planning and the Historic Environment and PPG 16: Planning and Archaeology. The aim is to streamline policy, which previously amounted to a combined total of 150 pages, the replacement Planning Policy Statement has more than halved. A review of such policy documents is often welcomed but it contains some serious flaws. The problems arise at least in part because the Government seems to be trying to introduce a lot of the changes, which were in the abandoned / delayed Heritage Bill, by the back door.

The most significant change suggested is the protection of non-listed buildings with architectural merit, such as Locally Listed Buildings. These are referred to as ‘heritage assets’. A heritage asset is described as “a building, monument, site or landscape of historic, archaeological, architectural or artistic interest, whether designated or not”. This will inevitably create uncertainty as Local Authorities are therefore able to take a broad interpretation of a ‘heritage asset’ in order to refuse applications that will have an impact on such a building or landscape. This is particularly significant for developers with sites in built up areas such as Brighton and Hove, where there is a high proportion of historically important buildings as a greater emphasis will be placed on the protection on non-designated buildings which are considered to be of interest.

We support the need to protect our heritage and welcome revisions to the existing policy, but it should not result in ambiguous meanings which can lead to the unnecessary refusal of planning applications. As such, DMH Stallard LLP will be making submissions on the draft PPS 15. The consultation period runs until 30th October 2009.