Under the new planning framework, why is the government picking a fight with heritage?
CLA Senior Heritage Adviser Jonathan Thompson suggests how the government should be supporting heritage in the new National Planning Policy Framework (NPPF), not hindering it
The draft new National Planning Policy Framework (NPPF), released for consultation in December 2024, includes some big changes for the planning system. Many of the proposals could work well (the CLA response is here), but nobody expected the NPPF to fundamentally change national heritage planning policy.
Currently, heritage planning policy is the part of the heritage protection system that broadly works well, thanks to years of work by Historic England, earlier governments, the CLA, the Institute of Historic Building Conservation and many others. We were therefore astonished to find wholesale and unexplained changes which would stop it working well.
National heritage planning policy mostly works – it’s the rest that doesn’t
The 2023 CLA/Historic Houses member heritage survey found, unsurprisingly, that 97% think heritage protection is important. Historic England’s figures echo that too. But, when asked how the actual heritage system (the whole system, not just national policy) works in practice, nearly half (48%) say it is ‘poor’ or ‘very poor’ – again matched by Historic England’s figures. Owners (private, public, and not-for-profit), and many others, are loudly stating that the system isn’t working.
If owners cannot manage, maintain and finance heritage, no amount of rhetoric about its ‘importance’ will save it. And since a third of planning applications involve heritage, a misfiring system – with heritage too often characterised as ‘a blocker’ – also hits desirable development and growth.
The system can work
The heritage sector, therefore, has been developing solutions which would both better protect heritage and support growth. For example, carefully drafted national listed building consent orders (LBCOs) could set out specific, effective and reversible works like draughtproofing and secondary glazing, and grant consent for them; finally unlocking the decarbonisation of heritage and rapidly building the still-embryonic skills base needed to do that well.
The government needs to help – not hinder
You might expect the government to be keen on widely-supported changes which boost both heritage and growth. So far however, in public at least, it has been completely resistant (or perhaps hasn’t fully turned its attention to heritage yet). For now, seemingly, all change is dangerous. This makes the new draft NPPF baffling as it makes three big unexplained changes to heritage policy, changes which truly would be dangerous.
First, the removal of viability from heritage policy (apparently this is a consequence of affordable housing policy). Viability has been in heritage policy for decades, but now it seems we can ignore the fact that heritage is expensive to run and needs viable uses to survive. Without explicit consideration of viability, a lot more heritage in the UK will decay.
Second is encouragement to local authorities to find that the changes needed to keep heritage used, valued and viable are probably ‘substantial harm’, so ought to be refused.
Thirdly is ‘preservation’, a formal presumption that changing heritage is bad, removed from policy in 2010, after extensive consultation because it didn’t work. But now, inexplicably, it’s back.
Each of these three mystifying changes would do real harm. National heritage policy has worked well without them for more than 16 years and they are entirely inconsistent with modern heritage good practice. And for what? Evidently not for heritage, nor for clarity and obviously not for growth. Simply more confusion, more cost, more conflict and more heritage in decay. The government is seemingly determined to preserve in aspic all the parts of the system which do not work, while tearing holes in an important aspect which, more or less, does.
We (and others) have written to the minister and made these points clear in the consultation. The CLA has had several meetings with officials and ministers, but the reasoning remains opaque.
These problems could readily be fixed. The heritage sector is already doing the heavy lifting; all the government needs is the will not to make the policy worse – and to help us all to make the rest of the system work. We will keep pushing.
