Introducing PPS5: Planning for the Historic Environment

Geoff Huntingford

In March 2010 the government cancelled its planning guidance for the historic environment and archaeology, PPGs 15 and 16, replacing both with a single policy statement: Planning Policy Statement 5: Planning for the Historic Environment (PPS5, 2010). This short document and its supplementary guidance PPS5 Historic Environment Planning Practice Guide introduces some radically new concepts, which are discussed briefly below. Both documents can be downloaded free of charge from the DCLG website.

Further articles on the implications of PPS5 for specific aspects of the historic environment will be published on this website and in Cathedral Communications' printed publications during 2010.

Important definitions

Heritage assets: 'Those parts of the historic environment that have significance because of their historic, archaeological, architectural or artistic interest are called heritage assets. Some heritage assets have a level of interest that justifies designation … this statement also covers heritage assets that are not designated but which are of heritage interest and are thus a material planning consideration' (paragraph 5).

A heritage asset is 'a building, monument, site, place, area or landscape positively identified as having a degree of significance meriting consideration in planning decisions. Heritage assets are the valued components of the historic environment. They include designated heritage assets as defined in this PPS (ie World Heritage Site, Scheduled Monument, Listed Building, Protected Wreck Site, Registered Park and Garden, Registered Battlefield or Conservation Area) and assets identified by the local planning authority during the process of decision-making or through the plan-making process (including local listing)' (Annex 2).

Significance is 'The value of a heritage asset to this and future generations because of its heritage interest. That interest may be archaeological, architectural, artistic or historic' (Annex 2).

Government objectives

First, to deliver sustainable development in the historic environment by recognising that heritage assets are a non-renewable resource, by taking account of the wider benefits of heritage conservation, and by recognising that intelligently-managed change may sometimes be necessary to maintain assets long term;

Second, to conserve assets in a manner appropriate to their significance by ensuring that decisions are based on that significance as investigated to a proportionate degree, by putting the assets where possible to an appropriate and viable use consistent with their conservation, recognising and valuing their contribution to local character and sense of place; and integrating the historic environment into planning policies;

Third, to contribute to our knowledge and understanding of our past by ensuring that evidence is captured and made publicly available.

Plan-making policies

Policy HE1: Climate change  Authorities should identify opportunities to mitigate and adapt to the effects of climate change in policies and decisions and enhance energy efficiency and the use of renewable energy; help applicants identify feasible solutions if sustainability may have a negative effect; and weigh the public benefit of mitigating climate change against harm to the asset where conflict between conservation and climate change objectives is unavoidable.

Policy HE2: Evidence base  Authorities should have publicly-documented evidence about the historic environment with proportionate level of detail, maintain or have access to a historic environment record (HER) and assess the assets in their area and their contribution to the environment now and in the future.

Policy HE3: Regional and local planning approaches  Plans should set out positive, proactive strategies for conservation and enjoyment of the historic environment, including their potential as a catalyst for regeneration and a stimulus to imaginative and high quality design, the reuse of existing fabric, and mixed and flexible land use patterns.

Policy HE4: Permitted development and article 4 directions  Article 4 directions should be considered if 'permitted development rights' would undermine the aims for the historic environment.

Policy HE5: Monitoring indicators  Authorities should consider how best to monitor and respond to the impact of their policies and decisions on the historic environment, including the risk of loss or decay.

Development management

Policy HE6: Information requirements for applications affecting assets  Authorities should require applicants to describe the significance of assets and the contribution of their setting. The level of detail should be proportionate to the importance of the asset and no more than is sufficient to understand the potential impact of the proposal on that significance. As a minimum, the HER should have been consulted and the asset assessed using appropriate expertise. Where assets include (or have the potential to include) archaeological remains, a desk-based assessment should be required from developers, or a field evaluation if this is insufficient.

These assessments of significance and of the impact of the proposal should be submitted with the application, with the sources considered and the expertise consulted.

Applications should not be validated if the impact on significance cannot be adequately understood from the application and supporting documents.

Policy HE7: Policy principles for the determination of consent relating to all assets Authorities should seek to identify and assess the significance of elements of the historic environment affected by the proposal by taking account of submitted evidence, other available information and, where appropriate, expert advice.

Authorities should avoid or minimise conflict between the proposals and the conservation of the asset by taking account of its significance and should seek the views of particular communities for whom the asset may have special significance.

They should take into account the desirability of new development making a positive contribution to the character and local distinctiveness of the historic environment.

They should discount deliberate neglect or damage caused in the hope of obtaining consent.

Where loss of significance is justified on the merits of the new development, the authority should take all reasonable steps to ensure development will proceed by means of condition or obligation by agreement.

Policy HE8: Additional policy principle for non-designated assets  If identifying an asset during the planning process, authorities should be clear that it meets the criteria in Annex 2. It is presumed that identification will occur during any pre-application discussion, otherwise the authority should assist applicants in identifying such assets at the earliest opportunity.

Policy HE9: Additional policy principles for designated assets and non-designated assets with archaeological significance  There should be a presumption in favour of the conservation of designated assets: the greater the significance, the greater the presumption. Significance can be harmed through alteration or destruction or development within its setting. Loss of significance needs clear and convincing justification. Substantial harm to Grade II listed buildings or registered parks or gardens should be 'exceptional': harm to everything else should be 'wholly exceptional'.

Authorities should refuse consent where substantial harm or total loss will occur unless it can be demonstrated that harm or loss is necessary to deliver substantial public benefits that outweigh the harm or loss; the nature of the asset prevents all reasonable uses of the site, no viable use can be found in the medium term, grant funding or charitable or public ownership is not possible, and the harm or loss is outweighed by the benefit of bringing the site back into use.

To be confident that no appropriate or viable use can be found, authorities should require evidence of appropriate marketing or reasonable endeavours to seek grant funding and to find charitable or public authorities willing to take on the asset.

If the proposal entails less than substantial harm to the asset, the authority should weigh the public benefit against the harm, recognising that greater justification is needed for greater harm.

The above principles apply to those elements in World Heritage Sites and conservation areas that contribute to the site's significance. If the element does not contribute, the authority should consider the desirability of enhancing or better revealing the significance of the location as part of the process of place-shaping.

Policy HE10: Additional policy principles for the settings of designated assets  Authorities should treat favourably proposals that contribute to the setting of the asset or better reveal its significance. Any harm must be weighed against wider benefits: the greater the negative impact, the greater the justification required.
Authorities should identify opportunities for changes in setting that enhance or better reveal significance as a public benefit and a part of place-shaping.

Policy HE11: Enabling development  Authorities should assess whether the benefits of securing the future conservation of an asset outweigh departing from the development plan or other national policies, also taking into account the criteria in the English Heritage guidance 'Enabling Development and the Conservation of Significant Places' (2008).

Policy HE12: Policy principles guiding the recording of information  A record is not as valuable as retention of the heritage asset, so the ability to record should not be a factor in the decision to allow the destruction of an asset.

Investigating significance should add to the evidence base for further planning and understanding. Authorities should make results available, including through the HER.

Where the whole or a material part of an asset's significance is to be lost, authorities should by condition or obligation require the developer to record it. The extent of the requirement should be proportionate to the nature and level of significance. The reports should be published and deposited with the HER. It should be required by condition or obligation that any archive generated must be deposited with a local museum or other suitable public depository.


The Building Conservation Directory 2011


Geoff Huntingford BSc(Hons) MA MRTPI IHBC has worked as a conservation officer for South Staffordshire District Council and for Sheffield City Council. He moved into private practice with McCoy Associates in 1985, and is currently conservation planner at West Waddy ADP, architects and town planners in Abingdon, Oxfordshire. He can be contacted by email at

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