41149 BSJConsJanFeb11_Q8 amended_BSJCons JanFeb2011 07/12/2010 15:19 Page 6

PPS5 Practitioner views

From the PPS5 frontline...

New government policy always creates uncertainty and its application usually needs some bedding in. Almost a
year after it was published, Les Pickford talks to four practitioners about the impact of PPS5 on the heritage sector

The IHBCs view

The response to PPS5 has, overall, been a
sense of relief. Though superficially similar to
the draft issued in October 2009, PPS5 is
more coherent and consistent and has been
substantially reshaped following comments
from the IHBC and the wider conservation sector. The joint IHBC-RTPI
response led to Planning Minister John Healey announcing that The
current language in the planning policy statement is not clear enough.
We will redraft it to make clear that the protection of heritage buildings
will not be reduced.
Continuity with existing policy practice has been a key issue in the
revision of the PPS PPG15 was intended not only for local authorities,
but also for property owners, developers, investors, etc and connections
between the two remain strong.
The new use of the term significance is intended to link to the terms
used in the 1990 Act (such as special architectural and historic interest),
which was presaged by PPG16. The intention is that all policies cover all
assets and so, to validate applications, the significance of heritage assets

The significance of heritage

assets has to be assessed
to a proportionate level

PPS5

has to be assessed to a proportionate level. This formalises a process

of assessment used in practice and so the proportionate approach to
significance chimes well with much current practice. Also, the formal
application of the policy to locally listed or non-designated fabric
recognises the inherent sustainability of the historic environment, and is
already helping practitioners approach the management of historic areas
more effectively, though it is too easy to forget the links to wider
planning. PPS5 is just one aspect of planning policy so it is not the
exclusive reference for all historic environment policy. In this sense,
PPS5 integrates historic environment policy with wider planning policy.
It also responds to the IHBCs commitment to integrate specialist historic
environment practice with the wider planning system. However, as
other PPSs do not generally concentrate on the historic environment,
the emphasis has been lost for areas such as enforcement.
However, the removal of policies not thought directly related to
planning (e.g. building regulations and dangerous buildings) loses
valuable statements of priority over other legislation. The accompanying
Planning Practice Guide provides interpretation for the PPS and is a
material consideration, but the guidance is seen as more flexible and,
in any case, future amendment is anticipated.
Dr Sen OReilly is Director of the Institute of Historic
Building Conservation
director@ihbc.org.uk

PPS5

The conservation officers view

The worst thing about March 2010
was the loss of old certainties I
was familiar with PPG15 while PPS5
was unknown and published without
warning. However, unlike the draft
PPS15, the accompanying Planning
Practice Guide gave some of the
practical advice previously contained
in Annex C of PPG15.
So, what is life like with PPS5?
The strangeness has gone, although
I have resorted to quoting sections from the Planning (Listed Buildings
& Conservation Areas) Act 1990 when I couldnt find the relevant piece in
PPS5. An early English Heritage training course was helpful, particularly
in assuring us that the content of PPG15 was now in PPS5 and the
practice guide. It is good that all designated heritage assets are treated
in a unified way to reflect the legislation it was intended to supplement,
which helps everyone take a holistic view of the historic environment.
One improvement is that local assets are afforded greater protection,
as evidenced when Cheltenham Borough Council won an appeal against

Building Conservation Journal

January-February 2011

a development near the locally listed Sandford Lido. The Inspectors

decision in July stated: Clearly, the proposed development would neither
preserve nor enhance the character or appearance of the Conservation
Area. Further, the proposal would cause substantial harm to the
significance of both a designated and a non-designated Heritage Asset.
Another is that Policy HE6 is more specific than PPG15 3.4 and 4.18
and has helped make planning officers aware of what needs to be
included in design and access statements. Some applicants have found
this requirement difficult but it is not unduly onerous as they only need to
assess the significance of the part affected by the proposed change and
its impact on the significance of the asset as a whole. Obviously, the
more extensive the proposed changes the more elements will need to
be assessed and for major cases a conservation plan will be appropriate.
Some areas will be determined by case law, e.g. the difference between
harm and significant harm. I still keep PPG15 to hand, though, as it
contains guidance which is not in PPS5, e.g. on curtilage structures,
fixtures and fittings and ecclesiastical exemption.
Sin Hughes is a Conservation Officer with Tewkesbury Borough Council
sian.hughes@tewkesbury.gov.uk

S5

S5

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PPS5 Practitioner views

PPS5

The conservation surveyors view

In our environmentally conscious world,
the creative use of historic buildings
is one of the best types of green
development. This principle is upheld
by PPS5. It has a strong emphasis
on keeping historic buildings in active
use and must be applauded for urging
planning authorities to be flexible and
imaginative. The aim is to achieve a
healthy balance between protecting
the buildings special architectural
and historic interest and adapting it for different uses.
A key policy statement (Heritage Assets and Climate, HE1.2) is that:
Where proposals that are promoted for their contribution to mitigating
climate change have a potentially negative effect on heritage assets,
local planning authorities should, prior to determination, and ideally
during pre-application discussions, help the applicant to identify feasible
solutions that deliver similar climate change mitigation but with less
or no harm to the significance of the heritage asset and its setting.
All of us working with PPS5 should note that the successful
conservation of our heritage needs to be based on sustainable
development. Where PPS5 does have a serious problem is with
statements of significance. In my experience, conservation and historic
buildings officers are demanding statements that are not proportionate
to the works proposed or to the importance of the building concerned.

One size fits all seems to be the

mantra the reality is that this
could bring heritage conservation
into disrepute

One size fits all seems to be the mantra, with every possible piece
of information being required just in case something might be missed.
The reality is that this could bring heritage conservation into disrepute.
I find it relatively easy to write a proportionate statement of significance
being an ex-conservation officer I am old and experienced enough to
discuss with them what they actually need. But this may not be so easy
for a non-heritage surveyor faced with the request for such a statement.
I would like to see us all getting together to thrash out how a peace
treaty could be fashioned. That way, we might ensure that applicants,
the heritage world and building control officers can work together to
equate the new Part L with heritage and produce appropriate and
proportionate statements of significance that we can all live with.
Allen Gilham MRICS IHBC is the Surveyor of Historic
Buildings at Watts Group
allen.gilham@watts-int.com

PPS5

The heritage consultants view

My experience of working with
historic buildings and archaeology is
that PPS5 has not yet improved the
planning system but it has changed
my workload.
My archaeological colleagues in
LPAs perceive no significant difference
between PPS5 and PPG16, except
for the emphasis on providing
archaeological information predetermination. Consequently, most ask for more evaluations and desk
studies and have ceased relying on post-determination watching briefs.
This is a significant change for clients and their advisors because it
requires additional time at the pre-determination planning stage: desk
studies and evaluations can take weeks between breaking the turf and
submitting an acceptable report. Surveyors acting as lead or planning
consultants can expect to commission additional site investigation
works, which will affect their timetables and budgets. The situation
regarding post-determination mitigation works is unchanged: clients will
be required to pay the full costs of, for instance, full-scale archaeological
excavations and the analysis and academic publication of the results.

The biggest change has been regarding historic buildings. I have

experienced a dramatic increase in the number of instructions, but their
financial value has fallen. This is because I am interpreting PPS5 correctly
and preparing short heritage statements rather than the detailed record
surveys that conservation officers are requesting. The latter should be
commissioned only where the significance case has already been
demonstrated. Some conservation officers appear to be grasping PPS5
as a tool for extracting more information pre-determination, but without
any apparent understanding of its intellectual purpose; although many
have specifically asked for assessment surveys, i.e. an intellectual
analysis of a buildings significance based on visual survey and historical
research, which is what PPS5 requires.
Assessments of significance will always be subjective, no matter
how carefully worded the criteria. The real issue is the lack of intellectual
rigour in PPS5s application, as manifested in the blanket request for
non-analytical record surveys before the intellectual case for such works
has been made. There is hope for PPS5 but it will require a change of
approach from conservation officers, and the IHBC, and the introduction
of heritage issues in the academic and professional training of all
construction professionals.
Michael Heaton is a professional archaeologist specialising in the

The real issue is the lack of

intellectual rigour in PPS5s
application

analytical survey of historic buildings

mike@michaelheaton.co.uk

Related competencies include: T012, T051

January-February 2011

Building Conservation Journal